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FINAL 

ENVIRONMENTAL IMPACT STATEMENT 

VOLUME I 




KESTERSON PROGRAM 



U.S. Bureau of Reclamation, Mid-Pacific Region 

in cooperation with 
U.S. Fish and Wildlife Service 

and 
U.S. Army Corps of Engineers 



OCTOBER 1986 



120.01 
R299 
13528 
vol. 1 
1986 

MP 



FINM. 
ENVIPDNME3S1TAL IMPACT STATEMENT 

KESTERSON PROGRAM 
MERCED Alto FRESNO COUNTIES, CA 

Subnitted by: 

U. S. Department of the Interior 
Bureau ot Reclamation as lead agency 

In cooperation witii: 

U. S. Fish and Wildlife Service and 
U. S. Army Corps of Engineers 

Technical assistance provided by: 

CH2M Hill and 
Jones & Stokes Associates 

This Environmental Impact Statement (EIS) has been prepared to coiply 
with the National Environmental Policy Act (NEPA) and U. S. Bureau of Recla- . 
mation (USER) NEPA procedures, Executive Orders 11988 (floodplains) and 11990 
(wetlands) , and section 404 (r) of the Clean Water Act and the section 
404(b) (1) guidelines of that Act. This Final EIS and the Draft EIS, incorpor- 
ated as Volume II of the Final EIS, together constitute a coitplete document 
describing the full prcposal, its alternatives, and all significant environ- 
mental impacts. 

Kesterson Reservoir and the San Luis Drain (SID) are contaminated with 
selenium originating fron past agricultural drainwater discharges that ceased 
prior to June 30, 1986. Tlie Draft EIS described the environmental impacts of 
four alternative plans (Flexible Response, Inmobilization, Onsite Disposal, 
and Off site Disposal) , in addition to no action, for Kesterson Reservoir and 
SID cleanup and disposition, and potential mitigation actions. The No-Action 
Alternative is included in the EIS as a baseline. It is not considered a 
viable alternative because it would not accorplish Kesterson Program purposes. 

The user's proposed action is a phased approach. The Flexible Response 
Plan will be inplemented first if the latest available research results indi- 
cate that the Flexible Response Plan may achieve cleanup goals within 1-5 
years. If water quality or biological monitoring indicates this plan is 
unsuccessful, the Immobilization Plan (pond option) will be irtplemented. If 
monitoring indicates the IniTK±)ilization Plan is also unsuccessful, the Onsite 
Disposal Plan will be inplanented with concurrent monitoring. 

For further information regarding this EIS, contact: Ms. Susan E. 
Hoffman, Program Manager, U. S. Bureau of Reclamation, 2800 Cottage Way, 
Sacramento, California 95825-1898, telephone 916/978-5046. 

Statement Number: ppe gg - 42 

Filing Date: ^^j 2q iggg -- 



SUMMARY 



Introduction 



The Final Environmental Impact Statement (EIS) for the 
Kesterson Program consists of two volumes, both of which should 
be considered to understand fully USBR's proposed action, alter- 
natives, and environmental impacts. The Draft EIS (Volume II of 
the Final EIS) was issued in April 1986. It evaluated the 
impacts of four alternative plans for Kesterson Reservoir and 
San Luis Drain (SLD) cleanup: the Flexible Response, Immobili- 
zation, Onsite Disposal, and Offsite Disposal Plans. 

This volume (Volume I of the Final EIS) presents a more 
detailed description of USBR's proposed action, and summarizes 
impacts of the proposed action. The proposed action is a phased 
approach incorporating elements of the Flexible Response, Immo- 
bilization, and Onsite Disposal Plans. This volume of the Final 
EIS also makes corrections and revisions to the Draft EIS, and 
presents responses to comments made on the Draft EIS. 

Proposed Action: Kesterson Reservoir 

The Draft EIS described a phased approach to Kesterson 
Reservoir cleanup involving elements of three plans (Flexible 
Response, Immobilization, and Onsite Disposal). Commenters on 
the Draft EIS requested more specificity about the components of 
the three plans and the decisionmaking process under the phased 
approach. Commenters on the Draft EIS also suggested refine- 
ments to each of the plans to reduce their environmental im- 
pacts. In response to these comments, this volume of the Final 
EIS presents a more detailed description of each plan, refine- 
ments made to each plan to reduce environmental impacts, and 
procedures for implementing the phased approach. 

Phased Approach 

Under the phased approach, USER proposes to implement the 
Flexible Response Plan (FRP) in March 1987 only if the latest 
available research results indicate that the FRP may achieve 
cleanup goals within 1-5 years. Selenium concentration goals 
for various media are as follows: 

o surface water - 5 yg/l (USFWS recommends 2 ug/1) 
o groundwater - 10 ug/1 

o waterfowl and mammal food chain items - 3 mg/kg 
o fish food chain items - 5 mg/kg 

o remaining sediments if Onsite Disposal Plan implemented 
- <4 mg/kg 



USER is proposing the phased approach because it has poten- 
tial for cost savings, leaves cleanup options open, and allows 
for consideration of the latest research results, until March 
1987, the date by which cleanup plan implementation will begin. 
By March 1987, the State Water Resources Control Board (SWRCB) 
is expected to have completed its review of the Closure and 
Post-Closure Maintenance Plan (CPMP) . Also, portions of the 
northern Reservoir will be dry enough by March 1987 to initiate 
the Onsite Disposal Plan, if selected initially for implementa- 
tion. 

The Immobilization Plan will be tested simultaneously with 
the FRP; it will be implemented if the FRP is not achieving 
cleanup goals and if test data indicate positive results for the 
Immobilization Plan. The Onsite Disposal Plan will be imple- 
mented if neither the FRP nor the Immobilization Plan will 
achieve cleanup goals. The Onsite Disposal Plan is designed to 
remove and encapsulate contaminated soils and vegetation, there- 
by substantially reducing risks of wildlife contamination. 

The Draft EIS describes certain potentially significant 
risks to fish and wildlife that are associated with the FRP (and 
the Immobilization Plan). Recognizing these risks, USER pro- 
poses to implement a phased approach, wherein these plans will 
be abandoned if monitoring shows that progress toward cleanup 
goals is not being achieved. Some scientists and commenters on 
the Draft EIS, however, believe that existing literature and 
research strongly suggest that the FRP (and Immobilization Plan) 
will clearly fail, and that risks to fish and wildlife assoc- 
iated with the plans are unacceptable. These issues are discus- 
sed in detail in the review of FRP impacts in Chapter 3 of this 
Final EIS. 



Flexible Response Plan 

The FRP was developed from the observation that almost all 
of the selenium that has been applied to Kesterson Reservoir via 
drainwater has been biologically or chemically accumulated in 
the Reservoir's sediments. Although half the water that has 
been applied to Kesterson Reservoir seeps into the groundwater, 
little groundwater contamination has been observed. 

The FRP is based on several assumptions: 1) selenium can 
be contained in the southern pond sediments by keeping them wet; 
2) wildlife exposure to contamination in the northern ponds can 
be reduced through vegetation management; and 3) clean water 
applied to the southern ponds will reduce the importance of a 
primary selenium exposure pathway (surface water) . 

Under the FRP, the southern six ponds that have regularly 
been wet under past operations will be kept wet. The source of 
applied water will be regional shallow groundwater. This water 
has moderate total dissolved solids (TDS) levels, and 



11 



concentrations of selenium that are less than 2 yg/1. As part 
of the FRP, Pond 4 will be used to evaluate the effectiveness of 
the Immobilization Plan in the southern ponds. 

The northern six ponds will not have applied water, but 
will be partially wet when the regional groundwater rises and 
will be dry the remainder of the year. Vegetation will be 
controlled with discing in the dry areas of the northern ponds 
(approximately 380 acres) ; a discing evaluation program is 
described in Chapter 2, Additional Research . 

As part of the FRP, an extensive monitoring program will be 
implemented. Components of the monitoring program will address 
groundwater, surface water, biota, air quality, and public 
health. 



Immobilization Plan 

If monitoring over the next 1-5 years indicates that clean- 
up goals will not be achieved under the FRP, the Immobilization 
Plan will be implemented if early tests show it to be feasible. 
If these tests show immobilization will not achieve cleanup 
goals, the Onsite Disposal Plan will be implemented directly 
after the FRP. 

Operation of the northern ponds under the Immobilization 
Plan will be similar to operation under the FRP. The Immobili- 
zation Plan is also similar to the FRP with regard to water 
operations in the southern ponds, except that greater pond 
depths will be maintained; also, ecosystem modification tech- 
niques, such as vegetation harvesting and selection of a parti- 
cular water depth to encourage or discourage selected vegeta- 
tion, will be implemented in the southern ponds. As with the 
FRP, an extensive monitoring program will be conducted. 

Onsite Disposal Plan 

If monitoring shows that neither the FRP nor the Immobili- 
zation Plan will achieve cleanup goals at Kesterson Reservoir, 
the Onsite Disposal Plan will be implemented no later than 1992. 
Onsite disposal calls for excavating all sediments (and associ- 
ated vegetation) with selenium concentrations >^4 mg/kg, and har- 
vesting all remaining above-ground vegetation. This material 
(approximately 450,000 cubic yards) will be deposited in an 
onsite lined and capped landfill which meets the requirements of 
Subchapter 15, Title 23 of the California Administrative Code. 



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Decisionmaking Process 

A flow chart of the proposed action and a summary of clean- 
up goals are shown in Figure S-1. The decision to implement a 
successive phase of the proposed action will be based on the 
results of the monitoring programs. Monitoring status reports 
will be prepared every 3 months, with semi-annual reassessments 
of the monitoring program. Annual progress reports will be 
submitted to the SWRCB. 

Annual decisions whether to continue with a particular 
phase will be made by the USER in consultation with the U. S. 
Fish and V^ildlife Service (USFWS) , and reviewed by the SWRCB, 
based on data from the monitoring programs. Quantitative annual 
selenium-reduction goals have not been established at this time 
because of the uncertainty with regard to rates of selenium 
concentration decline. 

Chapter 2 of this Final EIS describes the proposed action 
in greater detail. The final description of the proposed action 
will be contained in the CPMP to be submitted to the SWRCB on 
December 1, 1986. By that date, the Record of Decision for the 
Kesterson Program will be completed. 

Estimated costs of each of the plans (in 1986 dollars) are 
summarized in Table S-1. A footnote to Table S-1 describes 
incremental costs for various options of the Onsite Disposal 
Plan. 



Proposed Action; San Luis Drain 

USER is proposing to cover contaminated SLD sediments north 
of Manning Avenue with clean water, rather than excavate the SLD 
sediments, based on the following assumptions: 1) selenium can 
be contained in the SLD sediments; 2) application of clean water 
eliminates a primary selenium exposure pathway (surface water) ; 
and 3) there is a relative lack of vegetation, fish, and wild- 
life resources using the SLD. South of Manning Avenue, clean 
water will not be added to the SLD because SLD sediments south 
of Manning Avenue are not thought to be contaminated; this reach 
of the SLD has historically not been used for agricultural 
drainwater conveyance. 

Monitoring of groundwater, surface water, bxota, and public 
health m the SLD vicinity will be implemented as part of SLD 
management. Monitoring results may indicate a need to excavate 
contaminated SLD sediments. Disposal of SLD sediments could 
occur at Kesterson Reservoir as part of the Onsite Dispoal Plan; 
impacts of disposal of SLD sediments at Kesterson Reservoir were 
described in the Draft EIS evaluation of the Onsite Disposal 
Plan. If a decision is made to dispose of SLD sediments at an 
approved site other than Kesterson Reservoir, additional envir- 
onmental review would be necessary. 



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Table S-1. Annual Cost Summary 
(Thousands of Dollars) 



Alternative 
Plan 



Annual Cost 
Year 1 



Annual Cost 
Years 2-5 



Flexible Response Plan 

Capital costs 

Monitoring and 
operations 

Total 



300 

2,000 
2,300 



1,150 
1,150 



Immobilization Plan 

Capital costs 

Monitoring and 
operations 

Total 



4,200 

2,000 
6,200 



1,150 
1,150 



Onsite Disposal Plan 

Capital costs 

Monitoring and 
operations 

Total 



16,150 



1,750 
17,900 



700 



700 



Note: Costs do not include mitigation (estimated to be up 
to $10 million in capital costs for mitigation 
recommended by USFWS) . 

Adding onsite disposal of SLD sediments to the proposed 
action would add approximately $5 million to capital 
costs. Excavating 1 million cubic yards of sediments and 
vegetation at Kesterson Reservoir and disposing onsite 
would add approximately $24 million to capital costs. 
Disposal of SLD sediments at an approved site other than 
Kesterson Reservoir would add approximately $12 million 
to capital costs. 



VI 



USFWS Conunents on Proposed Action 

In its comment letter of July 8, 1986, the USFWS indicated 
that its environmentally preferred alternative for Kesterson 
Reservoir cleanup was an Offsite Disposal Plan. Because of the 
lack of available offsite landfills with sufficient existing 
capacity, the possible need for USER condemnation activities to 
implement offsite disposal, and the substantial costs associated 
with offsite disposal, the USFWS has developed a modified envir- 
onmentally preferred alternative which is described below. 

This alternative includes a state-of-the-art onsite dis- 
posal facility to contain up to 1 million cubic yards of 
Kesterson Reservoir contaminated soils, sediments, and vege- 
tation. Contaminated materials are defined as follows: 



o 



o 



Soils (includes decomposed, consolidated organic mat- 
ter) : all material with total selenium greater than 
4 mg/kg (dry weight) ; 

Vegetation and sediment (includes vegetative detritus 
and other unconsolidated organic matter) : all material 
(above and below ground) with total selenium greater 
than 3 mg/kg (dry weight) . 

The site would be monitored to assure that selenium levels in 
water, plants, soils, and biota do not exceed effects levels. 

To be acceptable to USFWS as the environmentally preferred 
alternative, these actions would be coupled with the following 
concurrent activities: 1) removal of Kesterson Reservoir from 
the Kesterson National Wildlife Refuge (NWR) and the National 
Wildlife Refuge System; 2) immediate and complete offsite miti- 
gation for the loss of the Kesterson Reservoir wetland habitat 
acreage and value (1,280 acres and value); 3) compensation for 
impacts to candidate and endangered species as discussed in the 
USFWS Biological Opinion on the Kesterson Program; and 4) con- 
tinuation of nuisance abatement actions, such as hazing and the 
provision of alternative habitat to draw birds away from the 
Reservoir, as long as such actions are deemed necessary. 

In the case of the SLD, the USFWS 's environmentally pre- 
ferred alternative is the offsite disposal, in an environment- 
ally acceptable manner, of the SLD sediments north of Manning 
Avenue. Once the contamination levels in the SLD south of 
Manning Avenue have been characterized, the USFWS will propose 
an environmentally preferred alternative for that reach. 

Environmental Impacts, Mitigation Measures, 
and Environmental Commitments 

Chapter 3 of the Final EIS discusses environmental impacts, 
mitigation measures, and environmental commitments under the 
proposed action. These topics are summarized below. 

vii 



Environmental Impacts 

Potentially significant impacts associated with the FRP , 
Immobilization Plan, and Onsite Disposal Plan are listed below. 
All impacts are capable of mitigation except those identified 
with a double asterisk (**), which are unavoidable. 

Flexible Response Plan 

Kesterson Reservoir ; 

o Continuation of hazing noise ** 

o Selenium leaching, and risks of groundwater contamina- 
tion, in the northern ponds similar to no action 

o Rising groundwater with initially high selenium concen- 
trations covering 230 acres of the northern ponds sea- 
sonally 

o Reduced, but continued, risks of contamination of vege- 
tation and wildlife (differences of opinion exist as to 
the magnitude of these risks) ** 

o Reduced, but continued, risks of contamination of rees- 
tablished fisheries (differences of opinion exist as to 
the magnitude of these risks) 

o Reduced, but continued, wildlife use of the Reservoir 

o Loss of 380 acres of wetland vegetation and wildlife 
habitat in the northern ponds due to drying (of the 
approximately 1,240 net acres of Reservoir wetlands, 380 
acres in the northern ponds will convert to upland 
habitat, 230 acres in the northern ponds will be season- 
al wetlands, and 630 acres in the southern ponds will be 
permanently wet) 

o Continued loss of prior, artificially created Reservoir 
fisheries habitat in the northern ponds 

o Potential continued loss of use of Reservoir wetlands 
tor recreational and wildlife uses, and potentially 
reduced short-term recreational opportunities at duck 
clubs due to hazing 

o Short-term potential for continued perception of reduced 
quality of life experienced by residents of Gustine and 
those adjacent to the Reservoir 

o Changes in the visual character of the Reservoir from 
discing ** 

San Luis Drain : 

o Reduced, but continued, risks of contamination of SLD 
vegetation, fisheries, and wildlife from SLD sediments 
(differences of opinion exist as to the magnitude of 
these risks) 

Offsite Mitigation Parcels : 

o Potential conversion of prime farmland to wetlands on 
offsite mitigation parcels 



Vlll 



o Possible effects on unidentified cultural resources at 
the offsite mitigation parcels 

Immobilization Plan 

Kesterson Reservoir ; 

o Continuation of hazing noise ** 

o Selenium leaching, and risks of groundwater contamina- 
tion, in the northern ponds similar to no action 

o Rising groundwater with initially high selenium concen- 
trations covering 230 acres of the northern ponds sea- 
sonally 

o Reduced, but continued, risks of contamination of vege- 
tation and wildlife (differences of opinion exist as to 
the magnitude of these risks) ** 

o Reduced, but continued, risks of contamination of rees- 
tablished fisheries (differences of opinion exist as to 
the magnitude of these risks) 

o Reduced, but continued, wildlife use of the Reservoir 

o Loss of 380 acres of wetland vegetation and wildlife 
habitat in the northern ponds due to drying (of the 
approximately 1,240 net acres of Reservoir wetlands, 380 
acres in the northern ponds will convert to upland 
habitat, 230 acres in the northern ponds will be sea- 
sonal wetlands, and 630 acres in the southern ponds will 
be permanently wet) 

o Continued loss of prior, artificially created Reservoir 
fisheries habitat in the northern ponds 

o Potential continued loss of use of Reservoir wetlands 
for recreational and wildlife uses, and potentially 
reduced short-term recreational opportunities at duck 
clubs due to hazing 

o Short-term potential for continued perception of reduced 
quality of life experienced by residents of Gustine and 
those adjacent to the Reservoir 

o Changes in the visual character of the Reservoir from 
discing ** 

San Luis Drain ; 

o Reduced, but continued, risks of contamination of SLD 
vegetation, fisheries, and wildlife from SLD sediments 
(differences of opinion exist as to the magnitude of 
these risks) 

Offsite Mitigation Parcels ; 

o Potential conversion of prime farmland to wetlands on 

offsite mitigation parcels 
o Possible effects on unidentified cultural resources at 

the offsite mitigation parcels 



IX 



Onsite Disposal Plan 
Kesterson Reservoir : 

o Potential ground-settling damage to onsite landfill 
liner 

o Short-term particulate (dust) emissions from excavating 
site soils and landfill construction 

o Short-term heavy equipment noise from excavation and 
landfill construction 

o Reduced, but continued, wildlife use of the Reservoir 

o Continued loss of prior, artificially created Reservoir 
fisheries habitat 

o Loss of a total of 820 acres of wetland vegetation and 
wildlife habitat in both northern and southern ponds due 
to drying and landfill construction (of the approximate- 
ly 1,240 net acres of Reservoir wetlands, 780 acres will 
be converted to upland habitat, 40 acres will be used 
for landfill and buffer, and 420 acres will be seasonal 
wetlands) 

o Continued loss of use of Reservoir wetlands for recrea- 
tional and wildlife uses 

o Short-term potential for continued perception of reduced 
quality of life experienced by residents of Gustine and 
those adjacent to the Reservoir 

o Changes in the visual character of the Reservoir from 
construction activities, onsite landfill, and drying of 
southern ponds ** 

San Luis Drain ; 

o Reduced, but continued, risks of contamination of SLD 
vegetation, fisheries, and wildlife from SLD sediments 
(differences of opinion exist as to the magnitude of 
these risks) 

Offsite Mitigation Parcels ; 

o Potential conversion of prime farmland to wetlands on 

offsite mitigation parcels 
o Possible effects on unidentified cultural resources at 

the offsite mitigation parcels 

Mitigation Measures and Environmental Commitments 

USER has identified mitigation measures capable of reducing 
or avoiding the environmental impacts of its proposed action. 
It has recommended many of these mitigation measures for imple- 
mentation. These recommended mitigation measures represent USER 
environmental commitments, as identified in Chapter 3. 

In general, impacts associated with risks of groundwater 
contamination will be mitigated to less-than-signif icant levels 



m 



by implementation of a corrective-action program (i.e., ground- 
water extraction) if monitoring indicates contamination. Also, 
the purchase of appropriate surrounding private lands will be 
considered if it is later determined that the influence of 
Kesterson Reservoir on groundwater is adversely affecting such 
lands to an extent that justifies such action, or if other 
programmatic purposes justify this action. This action would 
also further mitigate any quality of life impacts caused by 
cleanup activities, such as hazing and construction noise, dust, 
and traffic. 

Impacts associated with continued risks of biota contamina- 
tion will be partially mitigated by nuisance abatement activ- 
ities and implementation of an alternative plan if monitoring 
indicates that selenium-reduction goals are not achieved. 
Long-term wetland mitigation measures to recreate habitat values 
provided by Kesterson Reservoir prior to its contamination by 
subsurface agricultural drainage are being considered by the 
Department of the Interior (DOI) . Alternatives being considered 
by the DOI include provision of a new water supply to existing 
wetlands and/or purchase and development of off site wetlands. 
USFWS recommends mitigation consisting of the establishment of 
1,280 acres of new wetlands of comparable value to Kesterson 
Reservoir prior to contamination. 



XI 



TABLE OF CONTENTS 

Page 

SUMMARY i 

Introduction i 

Proposed Action: Kesterson Reservoir i 

Phased Approach i 

Flexible Response Plan ii 

Immobilization Plan iii 

Onsite Disposal Plan iii 

Decisionmaking Process iv 

Proposed Action: San Luis Drain iv 

USFWS Conunents on Proposed Action vii 

Environmental Impacts, Mitigation Measures, 

and Environmental Commitments vii 

Environmental Impacts viii 
Mitigation Measures and Environmental 

Conmiitments x 

CHAPTER 1 - INTRODUCTION 1-1 

Purpose of Final EIS 1-1 

Public Review ot Draft EIS 1-1 

Contents of Final EIS 1-1 

Endangered Species Act Compliance 1-2 

CHAPTER 2 - PROPOSED ACTION 2-1 

Phased Approach 2-1 

Flexible Response Plan 2-2 

General Description 2-2 

Water Supply 2-4 

Operation 2-4 
Nuisance Abatement Program (Short-Term 

Mitigation) 2-7 

Land Use 2-10 

Mitigation 2-11 

Biota Monitoring Program 2-12 

Groundwater Monitoring Program 2-22 

Air Quality Monitoring Program 2-2 6 

Surface Water Monitoring Program 2-30 

Public Health Monitoring Program 2-30 

Immobilization Plan 2-33 

General Description 2-33 

Water Supply 2-34 

Operation 2-34 



xii 



TABLE OF CONTENTS (Continued) 



Page 

Nuisance Abatement Program (Short-Term 

Mitigation) 2-34 

Land Use 2-34 

Mitigation 2-34 

Biota Monitoring Program 2-34 

Groundwater Monitoring Program 2-3 5 

Air Quality Monitoring Program 2-35 

Surface Water Monitoring Program 2-35 

Public Health Monitoring Program 2-3 5 

Onsite Disposal Plan 2-35 

General Description 2-35 

Landfill Construction 2-36 

Leachate Collection and Disposal 2-40 

Water Supply 2-41 

Operation 2-41 
Nuisance Abatement Program (Short-Term 

Mitigation) 2-42 

Land Use 2-42 

Mitigation 2-42 

Biota Monitoring Program 2-43 

Groundwater Monitoring Program 2-4 3 

Air Quality Monitoring Program 2-43 

Surface Water Monitoring Program 2-43 

Public Health Monitoring Program 2-43 

SLD Management Plan 2-43 

Biota Monitoring Program 2-44 

Groundwater Monitoring Program 2-45 

Air Quality Monitoring Program 2-45 

Surface Water Monitoring Program 2-45 

Public Health Monitoring Program 2-46 

Research 2-46 

Overview 2-46 

Ongoing Research 2-46 

Additional Research 2-47 

Summary of Costs 2-48 

CHAPTER 3 - ENVIRONMENTAL IMPACTS, MITIGATION MEASURES, 

AND ENVIRONMENTAL COMMITMENTS 3-1 

Introduction 3-1 

Summary of Environmental Impacts 3-1 

Flexible Response Plan 3-1 

Immobilization Plan 3-21 

Onsite Disposal Plan 3-22 

Mitigation Measures 3-24 



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p 
p 
p 



TABLE OF CONTENTS (Continued) 



Page 



Environmental Commitments 

Topography, Geology, and Soils 

Air Quality 

Noise 

Groundwater 

Surface Water 

Vegetation 

Fisheries 

Wildlife 

Land Use 

Population, Housing, and Social 

Environment 
Public Health 

Recreation and Transportation 
Energy 
Cultural Resources 



3-30 

3-30 
3-30 
3-31 
3-31 
3-32 
3-32 
3-32 
3-33 
3-33 

3-33 
3-34 
3-34 
3-34 
3-35 



CHAPTER 4 - ERRATA TO DRAFT ENVIRONMENTAL 
IMPACT STATEMENT 



4-1 



CHAPTER 5 - RESPONSES TO COMMENTS RECEIVED ON THE DRAFT 
ENVIRONMENTAL IMPACT STATEMENT 



5-1 



Agencies and Individuals Commenting in Writing 
on the Draft Environmental Impact Statement 
Federal Agencies 
State Agencies 
Local Agencies 

Other Agencies and Organizations 
Individuals 
Comments and Responses 
Response to Comirients of the Bureau of 

Indian Affairs 
Response to Comments of the Bureau of Land 

Management 
Response to Comments of the U. 

Wildlife Service 
Response to Comments of the U. 

Survey 
Response to Comments of the U. 

Engineers 
Response to Comments of the U. 

Protection Agency 
Response to Comments of Assemblyman Rusty Areias 
Response to Comments of the California Department 
of Fish and Game 



Fish and 
Geological 
Army Corps of 
Environmental 



5-1 
5-1 
5-1 
5-1 
5-1 
5-2 
5-3 

5-5 

5-7 

5-31 

5-51 

5-69 

5-79 
5-87 

5-91 



XIV 



TABLE OF CONTENTS (Continued) 



Page 

Response to Comments of the California Department 

of Health Services 5-94 

Response to Comments of the California Department 

of Health Services 5-102 

Response to Comments of the State Office of 

Historic Preservation 5-105 

Response to Comments of the Resources Agency of 

California 5-107 

Response to Comments of the California Regional 

Water Quality Control Board, Central Valley 

Region 5-113 

Response to Comments of the State Water Resources 

Control Board 5-116 

Response to Comments from the City of Gustine 

Incorporating Comments of the Merced County 

Department of Health 5-121 

Response to Comments of the Contra Costa Water 

District 5-125 

Response to Comments of the Fresno County Public 

Works and Development Services Department 5-131 

Response to Comments of the Kern County Department 

of Planning and Development Services 5-134 

Response to Comments of Merced County Counsel 5-139 
Response to Comments of the California Waterfowl 

Association 5-143 

Response to Comments of the Chapman Forestry 

Foundation 5-146 

Response to Comments of the Defenders of Wildlife 5-150 
Response to Comments of the Environmental Defense 

Fund 5-155 

Response to Comments of the Land Preservation 

Association 5-160 

Response to Comments of the National Audubon 

Society 5-163 

Response to Comments of the Natural Resources 

Defense Council 5-182 

Response to Comments of the Red Tape Abatement, 

Ltd. 5-190 

Response to Comments of the Sierra Club 5-198 

Response to Comments of David R. Dawdy 5-207 

Response to Comments of Doris Ostrander Dawdy 5-216 
Response to Comments of Alice Q. Howard 5-220 

Response to Comments of Jeff Kerry 5-222 

Response to Comments of Ivan H. Roscoe 5-224 

Response to Comments of Ferdinand S. Ruth 5-226 



XV 



TABLE OF CONTENTS (Continued) 



Page 

Response to Comments of Jan Whittington 5-23 4 

Response to Public Hearing Comments 5-236 

Summary of Public Hearings 5-236 

Issues Raised in Testimony 5-237 

Issues Raised as Questions 5-237 

Response to Oral Comments: Kesterson Public 

Hearings 5-240 

CHAPTER 6 - REFERENCES 6-1 

References Cited 6-1 

Personal Communications 6-6 

CHAPTER 7 - AGENCIES AND INDIVIDUALS RECEIVING COPIES OF 

THE DRAFT AND FINAL EIS 7-1 

Federal Agencies 7-1 

U. S. Department of the Interior 7-1 

Other Federal Agencies 7-1 

U. S. Senators 7-1 

U- S. Congress 7-2 

State Agencies 7-3 

State Senate 7-3 

State Assembly 7-3 

State Agencies (California) 7-3 

Local Agencies 7-4 

Other Agencies and Organizations 7-4 

Individuals 7-5 

Newspapers 7-7 

Libraries 7-8 



XVI 



LIST OF TABLES 

Table Page 

S-1 Annual Cost Summary vi 

2-1 Target Water Surface Elevations for 2-3 

Flexible Response Plan, Southern Ponds 

2-2 Well Information for Kesterson Reservoir 2-6 

Water Supply 

2-3 Water Budget for Wet Ponds: Flexible 2-8 

Response Plan (1982-84 Data) 

2-4 Habitat Types at Kesterson Reservoir 2-18 

2-5 Proposed Sampling Areas and Sampling 2-19 

Intensity for the Synoptic Surveys 

2-6 Preliminary Groundwater Analyses Parameter 2-27 
Sets for Post-Closure Monitoring Program 
at Kesterson Reservoir 

2-7 Groundwater Monitoring Schedule for 2-28 

Post-Closure Monitoring Program at 
Kesterson Reservoir 

2-8 USBR Monitoring Sites, Northern Grassland 2-31 
Water District 

2-9 Annual Flexible Response Plan Costs 2-49 

2-10 Annual Immobilization Plan Costs 2-50 

2-11 Annual Onsite Disposal Plan Costs 2-51 

3-1 Summary of Major Impacts of Alternative 3-2 

Plans 

3-2 Kesterson Program Mitigation Measures 3-25 



XV 11 



LIST OF FIGURES 

Figure 

S-1 Flow Chart of Proposed Action 

2-1 Shallow Well Locations 

2-2 Disced Areas of Ponds 6, 8-12 

2-3 Kesterson Reservoir Shallow Groundwater 
Selenium Concentrations 

2-4 Well Locations, Post-Closure Monitoring 
Program, Kesterson Reservoir 

2-5 Kesterson Reservoir Soil Selenium 2-37 

Levels 

2-6 Typical Cross-Section of Disposal Site 2-39 



Page 


V 


2-5 


2-9 


2-24 


2-25 



XVlll 



BEGIONAL LIBRARY 



Chapter 1 



INTRODUCTION 



Purpose of Final EIS 

The Final EIS for the Kesterson Program consists of two 
volumes, both of which should be considered to underst md fully 
user's proposed action, alternatives, and environmental impacts. 
The Draft EIS (Volume II of the Final EIS) was issued in April 
1986. It evaluated the impacts of four alternative plans for 
Kesterson Reservoir and SLD cleanup: the Flexible Response, 
Immobilization, Onsite Disposal, and Offsite Disposal Plans. 

This volume (Volume I of the Final EIS) presents a more 
detailed description of USBR's proposed action, and summarizes 
impacts of the proposed action. The proposed action is a phased 
approach incorporating elements of the Flexible Response, Immo- 
bilization, and Onsite Disposal Plans. This volume of the Final 
EIS also makes corrections and revisions to the Draft EIS, and 
presents responses to comments made on the Draft EIS. 



Public Review of Draft EIS 

The public review period for the Draft EIS ended on 
June 30, 1986. Written comments received by June 30, and sev- 
eral days thereafter, are reproduced in Chapter 5 of the Final 
EIS, together with USER responses. In addition, USER conducted 
three public hearings in Los Bancs, Fresno, and Gustine on the 
Draft EIS. Oral comments received at these public hearings are 
also reproduced in Chapter 5, together with USER responses. 

Contents of Final EIS 

This Final EIS contains seven chapters. Following this 
Introduction (Chapter 1) , Chapter 2 presents a detailed descrip- 
tion of user's proposed action, as refined. Chapter 3 summar- 
izes environmental impacts of the proposed action, as refined, 
and describes mitigation measures under consideration and USER 
environmental commitments. Chapter 4 contains the errata for 
the Draft EIS. Chapter 5 presents written and oral comments 
received on the Draft EIS and USER responses to these comments. 
Chapter 6 is a list of references cited in this Final EIS, that 
were not previously included in the Draft EIS references sec- 
tion. Chapter 7 lists agencies and individuals receiving copies 
of the Draft EIS and Final EIS. 



1-1 



Endangered Species Act Compliance 

On August 15, 1986, the USER submitted a Biological Assess- 
ment of the Kesterson Program to USFWS. The Biological Assess- 
ment is incorporated by reference into the Final EIS. The 
Biological Assessment concluded that one listed endangered 
species, the San Joaquin kit fox, could be adversely affected by 
the proposed action. It proposed the partial funding of a USFWS 
study to determine the extent to which kit fox would be affected 
by Kesterson Reservoir contaminants, and alternative conserva- 
tion measures if the study shows kit fox populations are being 
contaminated . 

Because of the proposed action's potential adverse effects 
on the San Joaquin kit fox, the USBR has requested formal con- 
sultation with the USFWS pursuant to Section 7 of the Endangered 
Species Act. The USFWS Biological Opinion presents USFWS recom- 
mendations on conservation measures for listed and candidate 
species that could be adversely affected by the proposed action. 
These conservation measures will be discussed in the Record of 
Decision for the Kesterson Program. 



1-2 



Chapter 2 



PROPOSED ACTION 



Phased Approach 

Under the phased approach, USER proposes to implement the 
FRP in March 1987 only if the latest available research results 
indicate that the FRP may achieve cleanup goals within 
1-5 years. Selenium concentration goals for various media are 
as follows: 

o surface water - 5 yg/1 (USFWS recommends 2 ug/1) 
o groundwater - 10 yg/1 

o waterfowl and mammal food chain items - 3 mg/kg 
o fish food chain items - 5 mg/kg 

o remaining sediments if Onsite Disposal Plan implemented 
- <4 mg/kg 

USER is proposing the phased approach because it has the 
potential for cost savings, leaves cleanup options open, and 
allows for the consideration of the latest research results, 
until March 1987, the date by which cleanup plan implementation 
will begin. By March 1987, the SWRCB is expected to have com- 
pleted its review of the CPMP . Also, portions of the northern 
Reservoir will be dry enough by March 1987 to initiate the 
Onsite Disposal Plan, if this plan is selected initially for 
implementation . 

The Immobilization Plan will be tested simultaneously with 
the FRP; it will be implemented if the FRP is not achieving 
cleanup goals and if test data indicate positive results for the 
Immobilization Plan. The Onsite Disposal Plan will be imple- 
mented if neither the FRP nor the Immobilization Plan will 
achieve cleanup goals. The Onsite Disposal Plan is designed to 
remove and encapsulate contaminated soils and vegetation, there- 
by substantially reducing risks of wildlife contamination. 

The decisionmaking process for the phased approach is 
described in the Summary section of this Final EIS. Figure S-1 
presents a flow chart of the phased approach. 

The Draft EIS describes certain potentially significant 
risks to fish and wildlife that are associated with the FRP (and 
the Immobilization Plan). Recognizing these risks, USER pro- 
poses to implement a phased approach, wherein these plans will 
be abandoned if monitoring shows that progress toward cleanup 
goals is not being achieved. Some scientists and commenters on 
the Draft EIS, however, believe that existing literature and 



2-1 



research strongly suggest that the FRP (and the Immobilization 
Plan) will clearly fail, and that risks to fish and wildlife 
associated with the plans are unacceptable. These issues are 
discussed in detail in the review of FRP impacts in Chapter 3 of 
this Final EIS. 

Flexible Response Plan 



General Description 

The FRP was developed from the observation that almost all 
of the selenium that has been applied to Kesterson Reservoir via 
drainwater has been biologically or chemically accumulated in 
the Reservoir's sediments. Although half the water that has 
been applied to Kesterson Reservoir seeps into groundwater, 
little groundwater contamination has been observed. 

The FRP is based on several assumptions: 1) selenium can 
be contained in the southern pond sediments by keeping them wet; 
2) wildlife exposure to contamination in the northern ponds can 
be reduced through vegetation management; and 3) clean water 
applied to the southern ponds will reduce the importance of a 
primary selenium exposure pathway (surface water). 

Southern Ponds . Based on recent operational information 
(1982-85) , Ponds 1-5 and 7 have historically had the most ap- 
plied water. Pond water surface elevations will be kept within 
0.5 foot of target elevations, which are presented in Table 2-1. 

Pond 4 will be kept at approximately 1 foot under the 
design maximum water surface and will be used to evaluate the 
effectiveness of the Immobilization Plan concurrently with 
implementation of the FRP. Pond 4 is the preferred test pond 
because it already contains extensive Nitella areas, resembles 
Pond 5, which is intensively studied, borders on less private 
land, and does not appear to be leaching selenium into the 
groundwater. 

Initially, Ponds 6 and 8-12 will not have applied water. 
These ponds, with the exception of Ponds 6 and 8, generally have 
lower concentrations of selenium in soils and sediments. USER 
will review the feasibility of applying water to Ponds 6 and 8, 
and may decide to do so in order to further reduce possible 
risks of groundwater and wildlife contamination. 

Northern Ponds . Some areas within the northern ponds will 
be seasonally wet as a result of direct rainfall and rising 
groundwater in the low areas. The dry areas and the seasonally 
wet areas of the northern ponds will be treated differently. 

The dry areas (approximately 380 acres) will be disced as 
needed to control vegetation growth and wildlife habitat. A 
discing evaluation program is included in the Additional 

2-2 



Table 2-1. Target Water Surface Elevations 
for Flexible Response Plan, Southern Ponds 







Average 








Target 


Pond 


Design 


o 




Operation 


Elevation 


Maximum 


Pond Bottcm 




Elevation 


1982-84 


Water Surface 


Elevation 


Pond 


(feet) 


(feet) 


(feet) 


(feet) 


1 


76.5 


77.2 


78.0 


73.2 


2 


76.5 


77.0 


78.0 


73.2 


3 


76.0 


76.0 


77.5 


73.1 


4 


76.5 


76.0 


77.5 


71.6 


5 


75.5 


75.7 


77.0 


71.7 


7 


75.5 


74.5 


76.5 


72.5 



Note: Ponds 6 and 8-12 will not have applied water. 
Ninety perceait of surface area above elevation shewn. 



2-3 



Research section. The seasonally wet areas will be monitored to 
detect possible food chain contamination. If contamination does 
occur, the seasonally wet areas may be disced (if testing shows 
this to be effective) , harvested, or filled (see Immobilization 
Plan) . A maximum of 230 acres of seasonal wetlands in the north- 
ern ponds could be affected by these management actions. 

Under the FRP, drying of the northern ponds will convert 
about 380 acres of northern pond wetland habitat to upland 
habitat. The remaining 230 acres of the northern ponds will be 
seasonal wetlands. 



Water Supply 

During the summer of 1986, the USER constructed 10 shallow 
wells along the eastern edge of the Reservoir. The wells are at 
a 1,000-foot spacing near the access road along the west side of 
the SLD from the southern end of Pond 7 up through Pond 12 as 
shown in Figure 2-1. All of the wells were operating by August 
1986. The wells will discharge into the SLD and via the SLD 
into Pond 1 or Pond 2. From there, water can gravity flow into 
other southern ponds. 

Up to 10 additional wells will be drilled by the USER to 
supply additional water needed during the summer months and 
provide backup if several wells are not operational or if the 
yield from the existing wells diminishes. Table 2-2 is a summa- 
ry of the first 10 well facilities, flow rates, and current 
water quality in terms of electrical conductivity (EC) and 
selenium for the water supply to Kesterson Reservoir. 



Operation 

Southern Ponds . The southern ponds will be operated at the 
target water elevation plus 0.5 foot on May 1, and the water 
elevation will be allowed to drop to 0.5 foot below target water 
elevation on September 1. This will provide an additional 
0.5 foot of water for summer evaporation, and will allow a 
1-foot total evaporation loss over the summer months, which will 
lessen the peak flow pumping requirements. Average maximum 
monthly evaporation based on pan evaporation data from Kesterson 
Reservoir is 10.1 inches during July. Estimates of infiltration 
indicate a range of 2-7 inches per month during the period 
1982-84, or about 4.5 feet per year. The maximum average inflow 
needed to maintain water elevation with only a 3-inch drop per 
summer month is 712 acre-feet or 5,370 gallons per minute (gpm) . 

The operation will provide for minimum water elevation 
(target minus 0.5 feet) to occur about September 1. Evaporation 
decreases dramatically in October, and the 1 foot of additional 
storage will be available to store rainfall in excess of net 
evaporation and infiltration during the winter months. 



2-4 




• WELL LOCATIONS 

A PROPOSED ADDITIONAL WELLS 



FIGURE 2-1 

SHALLOW WELL LOCATIONS 



2-5 



Table 2-2. Well Information for Kesterson Reservoir Water Supply 



Well 

Nuinber 


Perforation 
Depth 
(ft) 


Discharge 

(yti") 


Electrical 

Conductivity 

(umhos/cm) 


Selenium 
(pg/1) 


1 


63-113 


320 


11,790 


1.6 


2 


63-113 


425 


6,160 


1.2 


3 


70-133 


480 


6,250 


0.9 


4 


63-133 


380 


5,280 


1.1 


5 


63-143 


425 


6,670 


0.2 


6 


63-113 


425 


5,320 


1.0 


7 


63-123 


425 


6,420 


0.3 


8 


63-113 


425 


7,460 


0.3 


9 


63-113 


475 


a 


0.7 


10 


70-130 


480 


a 


0.6 



Information not yet available. 

Most recent (September 1986) measurements. 



2-6 



Table 2-3 shows the general operation and water budget for the 
wet ponds based on Kesterson Reservoir data from 1982 to 1984. 

Hazing operations, including the use of cracker shells, 
scarecrows, propane exploders, and pyrotechnics, will continue 
until monitoring indicates that wildlife cleanup goals are 
achieved. 

Northern Ponds . The northern ponds will not have applied 
water. The dry areas of the northern ponds (approximately 380 
acres) will be disced as needed (see Figure 2-2 for discing 
locations) . Mammal use in these areas is expected to be reduced 
because of lack of food and cover. During the winter months, 
the lower areas within the northern ponds (approximately 230 
acres) may have shallow water as a result of rainfall, or 
groundwater rising to the surface. These seasonal wetland 
areas, shown in Figure 2-2, will be monitored to determine if 
food chain contamination occurs. Hazing will continue. 

Research to better evaluate selenium mobility in the north- 
ern ponds will be conducted in the fall of 1986 (see Addition- 
al Research section) • A small area will be disced to see if 
mixing the top 6-12 inches of soil and organic material will 
reduce the selenium mobility or concentration in the food chain. 
Discing will be implemented only if testing indicates it reduces 
food chain contamination. 

The discing procedure is as follows. On approximately 
March 15, or as soon as the soil has dried sufficiently to 
support vehicular traffic, the dry areas of the northern ponds 
will be disced. The area will be disced twice, the second 
discing perpendicular to the first. Additional double discing 
will be done as needed if late rainfall or soil moisture gener- 
ates substantial new vegetative growth. Standard agricultural 
equipment including track-laying and double-wheel tractors and 
large (16-24 foot) discs will be used. Discing depth will be 
between 6-12 inches. 

If discing is not successful in preventing food chain 
contamination in the dry areas of the northern ponds, then 
these areas may be harvested (see Immobilization Plan) . 

Nuisance Abatement Program (Short-Term Mitigation) 

The goal of the FRP nuisance abatement program is to reduce 
exposure of fish and wildlife resources to residual contamina- 
tion at Kesterson Reservoir during the cleanup process, or to 
compensate for any continuing exposure that is not avoided. 
Nuisance abatement activities described below will continue 
until selenium concentration goals in biota have been achieved. 



2-7 



Table 2-3. Water Budget for Wet Ponds: 

Flexible Response Plan 

(1982-84 Data) 











Operational 
Plan - 








Itonth 


Average 
Rainfall 
(inches) 


Average 

Evap. 
(inches) 


Infil- 
tration 
Estimate 
(inches) 


C3iange 
in Water 
Elevation 
(inches) 


Water 
Req'd 
(inches) 


Monthly 
Req'd 
(af) 


Pumping 
Req'd 
(gpri) 


Jan 


1.92 


1.00 


2.00 


+1 


2.08 


105 


790 


Feb 


1.71 


1.96 


2.00 


+3 


5.25 


265 


2,000 


Mar 


3.50 


3.35 


3.00 


+6 


8.85 


442 


3,370 


Apr 


1.20 


5.39 


4.00 


+2 


10.19 


515 


3,880 


May 


0.20 


9.69 


5.00 


-3 


11.49 


580 


4,370 


Jvme 


0.00 


9.99 


6.00 


-3 


12.99 


656 


4,950 


July 


0.00 


10.10 


7.00 


-3 


14.10 


712 


5,370 


Aug 


0.00 


8.94 


7.00 


-3 


12.94 


653 


4,930 


Sept 


0.69 


7.06 


6.00 





12.37 


625 


4,710 


Oct 


0.78 


2.04 


5.00 





6.26 


316 


2,380 


Nov 


1.83 


1.13 


4.00 





3.30 


167 


1,260 


Dec 


2.34 


.78 


3.00 





1.44 


73 


550 


TOTALS 


14.17 


61.43 


54.00 




101.26 


4,812 





2-8 



LEGEND 



^ 



AREAS THAT WILL BE DISCED 
TO CONTROL VEGETATION 

AREAS WHERE WATER MAY 
RISE ABOVE LAND 




I 





b 



1/4 



1/2 
MILE 



FIGURE 2-2 



DISCED AREAS OF PONDS 6,8-12 



2-9 



The following actions will be taken: 

o Hazing operations: continue until monitoring indicates 
there is no longer a significant threat to wildlife and 
waterfowl. 

o Northern pond actions: disc existing vegetation and 
emergent vegetation in dry areas (380 acres) ; monitor 
seasonal wetlands (230 acres) , and if contaminated, 
implement either discing, harvesting, or filling with 
uncontaminated offsite soils. 

o Southern pond actions: filling of ponds with low-selen- 
ium water; harvesting of cattail stands supporting 
tricolored blackbird colonies following enhancement of 
alternative habitat if the food chain continues to be 
contaminated . 

o Development of alternative habitat: 130 acres of alter- 
native wetland habitat on the east side of Kesterson NWR 
will be improved to lure tricolored blackbirds and other 
wildlife away from Kesterson Reservoir. 

o Partial funding of a USFWS study of local San Joaquin 
kit fox populations. 

The actions below are recommended by USFWS, and are under 
consideration by the DOI . 

o Provision of Central Valley Project (CVP) water to 
offsite wetlands: about 8,000-12,000 acre-feet of CVP 
water could be supplied annually to lands near Kesterson 
Reservoir for alternative habitat to lure waterbirds 
away from Kesterson Reservoir. The availability of CVP 
water from the Mendota Pool at times appropriate for 
this use is currently being investigated. 

About half the water could be used on the Volta and Los 
Banos Wildlife Areas; water could be supplied to these 
areas during the fall and winter to create wetlands and 
partially mitigate for lost hunting opportunities at 
Kesterson Reservoir. The remaining half of the water 
could be applied to lands in the vicinity of Kesterson 
Reservoir; water would be applied during spring and 
summer to create additional permanent waterfowl habitat 
and lure wildlife away from Kesterson Reservoir. 

Land Use 

Public access will be restricted. Monitoring will be used 
to determine contaminant levels in the biota. If cleanup goals 
are achieved, hazing will be discontinued and the southern ponds 
returned to wetland habitat conditions. An upland or seasonal 
wetland habitat could be established in the northern ponds. 



2-10 



Mitigation 

Under the FRP, two categories of mitigation actions are 
being considered. The first category (nuisance abatement or 
short-term mitigation) consists of actions intended to reduce 
exposure of fish and wildlife resources to contamination at 
Kesterson Reservoir during the cleanup process, or to compensate 
for any continuing exposure that is not avoided. The second 
category (long-term mitigation) involves actions to recreate the 
habitat values (wetland and upland) provided by Kesterson Reser- 
voir prior to its contamination by subsurface agricultural 
drainage. 

The final determinations as to the extent and processes of 
implementing mitigation actions in each category must await 
further data, as well as analysis of the nature and extent of 
the Secretary of the Interior's obligations and discretionary 
authority to undertake the various measures under consideration. 
This analysis will involve consideration of all laws adminis- 
tered by either the USFWS or the USER that may bear on the 
ultimate decisions, including the Fish and Wildlife Coordination 
Act, the National Wildlife Refuge System Administration Act, the 
Migratory Bird Conservation Act, the Endangered Species Act, the 
Migratory Bird Treaty Act, the Federal Water Project Recreation 
Act, and CVP authorizing legislation. 

Specific actions now under consideration in each category 
are described below. 

Short-Term Mitigation . See discussion of nuisance abate- 
ment program. 

Long-Term Mitigation . Measures under consideration by the 
DOI include the following: 

Continued Use of Alternative Habitat on East Side of 
Kesterson NWR . See discussion of nuisance abatement program. 

Provision of CVP Water to Off site Wetlands . See 
discussion of nuisance abatement program. 

Development of Gallo and/or Wolfsen Properties as 
Wetlands . Portions of these properties could be purchased or 
leased and developed as wetlands. Water supply could be CVP 
water or local onsite wells. See the Draft EIS for details 
regarding this alternative. 

USFWS Recommendations Regarding Mitigation . USFWS recom- 
mends that long-term mitigation measures be undertaken by USER 
immediately upon implementation of the phased approach. This 
recommended action includes the following: 

o Purchase of lands to accommodate the development of a 
minimum of 1,280 net acres for the loss of Kesterson 
Reservoir wetland habitat (this acreage would probably 



2-11 



include approximately 1,000 acres on the Gallo parcel 
and 600 acres on the Wolfsen parcel) 

o Development of these lands into manageable wildlife 
habitat 

o Provision of a permanent, quality water supply to these 
mitigation lands (approximately 10,000 acre-feet annual- 
ly of surface water and backup well water supplies) 

o Mitigation for the loss of the recreational use of 
Kesterson Reservoir (which may or may not be concurrent 
with habitat loss mitigation) 

o Compensation for impacts to candidate and endangered 
species as detailed in USFWS ' Biological Opinion. 



Biota Monitoring Program 

Objective . The objective of the Kesterson Reservoir bio- 
logical monitoring prograin is to determine when, or if, residues 
of selenium will decline to safe levels in Kesterson Reservoir 
biota. The selenium concentration goals for biota will be 
5 mg/kg (dry weight) for warmwater fish food chain organisms, 
and 3 mg/kg (dry weight) for waterfowl and mammal food chain 
organisms. The warmwater fish and waterfowl food chain Maximum 
Acceptable Toxicant Concentrations (MATCs) were recommended by 
USFWS (Wallenstrom pers . comm.), and will be further refined 
based on the results of future research. 

The small mammal food chain MATC is preliminary, and based 
on feeding studies cited in the Draft EIS (see p. 4H-22) . These 
mammal feeding studies showed chronic selenium toxicity at 
dietary levels of 5-10 mg/kg (Anspaugh and Robison 1971) , and 
8-30 mg/kg (Wilber 1984) . The 3 mg/kg goal is also based on 
selenium coiicentrations found in four abundant small mammal 
species at Volta Wildlife Area, a control area for Kesterson 
Reservoir; mean selenium concentrations in the tour species 
ranged from 0.2 to 2.67 mg/kg, with some individuals having 
selenium concentrations above 3.0 mg/kg. 

At least initially, USER proposes to sample only selenium 
in biota. Selenium has been identified as the primary contami- 
nant of concern in Kesterson Reservoir (see Draft EIS, Chap- 
ter 3) . Periodic analysis of other possible contaminants of 
concern will be made. 

Responsibilities . The initial monitoring program (des- 
cribed below) is being conducted by University of California, 
Berkeley/Lawrence Berkeley Laboratory (UCB/LBL) . The USFWS will 
have the opportunity to implement all or portions of the synop- 
tic surveys and the refined monitoring program (also described 
below) if it desires; otherwise the required studies will be 
conducted or coordinated by the USBR. Monitoring status reports 



2-12 



will be prepared every 3 months, with semi-annual reassessments 
of the monitoring progreon. Annual progress reports will be 
submitted to the SWRCB. 

Initial Biota Monitoring Program 

Objective . Baseline studies of the physical, chemi- 
cal, and biological limnology of Kesterson Reservoir were initi- 
ated during the fall of 1985 by UCB/LBL researchers. The objec- 
tives of these initial monitoring studies are to determine 
whether the proposed action results in a reduction of selenium 
mobility within the food web, and whether a decline in selenium 
levels at Kesterson Reservoir is occurring. The primary purpose 
of these studies is to generate both baseline and post-treatment 
data to predict when, or if, residues of selenium and other 
contaminants will decline to safe levels, and at what concentra- 
tions a steady-state condition will be achieved. 

Approach . Baseline data are prerequisite to any 
monitoring study, in that treatment effects can best be detected 
as departures from the pre-treatment condition. Baseline data 
for many taxa will only be available for ponds that v/ere sampled 
by UCB/LBL prior to June 30, 1986 (Ponds 5, 7, and 11); after 
that date interim management of the Reservoir resulted in the 
release of low-selenium water into Kesterson Reservoir. Samp- 
ling procedures for individual taxa (Hcrne 1986) are summarized 
below. 

Sampling Design and Data Analysis . Both wet and dry 
treatments have been proposed (wet ponds: 1-5 and 7; dry 
ponds: 6 and 8-12) under the FRP, and the UCB/LBL studies con- 
sider their effects on the four Kesterson Reservoir habitats 
defined by Wallenstrom (pers. comm.): 

1) Typically permanent, deep water wetland, including open 
water areas with Nitella , and dense emergent vegetation 
areas (Pond 5 and experimental Pond 5e enclosure) 

2) Typically seasonal, shallow water wetland, including 
emergent vegetation, other wetland plants, and saltgrass 
areas (Pond 7) 

3) Typically seasonal, shallow water "playa," including 
bare ground and areas which grow pond weeds when inun- 
dated (Ponds 11 and 12) 

4) Typically seasonally dry wetland/upland, but often with 
saturated soils, including saltgrass, and "upland" 
vegetation such as Atriplex (Ponds 11 and 12) 

Under the initial monitoring program, samples have been 
collected at Ponds 5, 7, and 11 by UCB/LBL researchers; these 
studies have been subdivided into the following sections by 
Home (1986) : 



2-13 



o Measurements of the 1985-86 baseline conditions (Ponds 

5, 7, and 11) 

o Measurements of the changes following the cessation of 
the inflow of agricultural drainwater (Ponds 5, 7, and 
11) 

o Measurements in the field of the more rapid changes in 
selenium levels in biota in small experimental enclo- 
sures following addition of selenium-free water during 
the summer of 1986 (Pond 5e) 

o Measurements in the field of the changes in selenium in 
biota, soils, and groundwater in the mostly dry areas 
(Ponds 11 or 12) using treatments of selenium-extracting 
or selenium-rejecting plant covers 

o Measurement in laboratory analogs of the dynamics of the 
selenium pathways in Kesterson Reservoir biota using 
indigenous organisms transplanted from the Reservoir 
(Ponds 5, 7, and 11) 

o Measurements of primary productivity of the existing 
marsh with emphasis on the partitioning of carbon fixa- 
tion and selenium associated with the aufwuchs and 
macrophyte communities 

Samples have been collected for most taxa at least once per 
month due to the seasonal and spatial flux in selenium concen- 
trations and to variations in the distribution of organisms. 
Detailed discussions of the sampling design, methodology, and 
statistical analysis of the UCB/LBL initial monitoring study are 
given by Home (1986). 

Sample Methods . The indicator species discussed below 
were selected by UCB/LBL researchers because they occur regular- 
ly at Kesterson Reservoir and because they are dominant elements 
in the food web. 

Plankton. (Ponds 5 and 5e) . Zooplankton are 
being collected by using a 30-cm diameter, 135-ym mesh net towed 
near the water surface from a moving boat. Tows are made in 
three randomly selected areas in open water. Three replicate 
1-minute tows are made during each sampling period. Samples are 
preserved in 4 percent formalin containing rose bengal stain. 

Phytoplankton are collected by dip-sampling the surface 
water and enclosing a 100-ml sample. Triplicate samples are 
taken at random points from open water areas; samples are pre- 
served in Lugols iodine solution. 

Both zooplankton and phytoplankton samples are counted and 
identified to species when possible. Typically, a subsample 
containing at least 200 individuals is counted. Due to the 



2-14 



scarcity of true plankton, selenium content is not measured 
routinely. 

Epiflora and Epifauna . (Ponds 5, 5e, 7, and 11). 
Because the epiflora and epifauna are physically intertwined in 
the submergent macrophyte vegetation (e.g., Nitella , Ruppia , and 
Zanichellia ) , these organisms are quantitatively sampled as a 
single unit. A . 25-square-meter floating quadrat is placed 
over an area of aquatic vegetation. A 10-cra square section is 
then cut from the sample, lifted gently, and placed in a col- 
lection bag which is at the water surface level. Three samples 
are collected on each date using a stratified sampling design; 
sample sites are 10 cm below the surface in green vegetation 
near the center of a large clump. 

A separate sample, representing 25 percent of the original 
sample, is removed from the water and transported to the labo- 
ratory. The aufwuchs community is separated from the macrophyte 
substrate by washing, and both fractions are dried and prepared 
for selenium analysis. A subsample is also washed to determine 
the relationship between wet weight, dry weight, and ash weight. 

Invertebrate samples are processed in the field because it 
is difficult to distinguish preserved organisms from similar- 
looking detritus. Epiflora and epifauna are washed from the 
macrophyte substrate by gentle shaking. Macrophyte strands are 
visually inspected for remaining animals, centrifuged to a 
constant water content, and weighed in the field. The liquid 
washings, containing both invertebrates and aufwuchs, are then 
filtered through nested 1.1-mm and 0.35-mm screens to remove 
epiflora and resuspended in clean pond water in large white 
sorting trays. All visible animals are picked out with forceps 
and placed into ice-cooled water. Major indicator species in 
these samples include: the herbivorous larvae of chironomid 
midges and the carnivorous larvae of predatory damselflies and 
dragonflies. Cranefly larvae, rat-tail maggots, and Stratiomyid 
larvae have also been sampled. 

Predators such as damselflies and dragonflies are separated 
from their prey and kept in cold containers for later food chain 
analysis. At the laboratory, these animals are anesthetized 
with carbon dioxide, sorted into taxonomic groups, counted, 
measured, weighed, dried, and processed for selenium analysis. 
A few individuals are dissected for gut content analysis. If 
pupae are present, samples are reared to adults since many 
aquatic insect larvae are impossible to identify at the species 
level. 

All epifaunal organisms (e.g., larvae of chironomids, 
damselflies, and dragonflies) are collected from under a known 
surface area and from a known biomass or macrophyte substrate. 
These animals can either be quantified as numbers or biomass per 
unit surface area of the macrophyte biomass. 



2-15 



Benthos . (Ponds 5, 5e , 7, and 11). Benthic 
invertebrates, such as the bactivorous and/or detritivorous 
ostracods and the larvae of herbivorous chironomids and soldier 
flies are the major indicator species sampled by UCB/LBL. These 
organisms are sampled using either an Ekman grab sampler for 
soft substrates or a petite ponar grab for firmer substrates. 
Triplicate samples are taken in both types of benthic sub- 
strates. These animals are separated from the detritus, sorted, 
and counted while still alive. Organisms are processed for 
taxonomic identification, pupal rearing, measurement of length, 
weight, and selenium content using the same methods as described 
for the epifaunal communities. 

Fish . (Ponds 5, 5e, 7, and 11). Mosquitofish 
( Gambusia ) have been sampled at least once per month since fall 
1985. Dip net samples from both the edge and open water habi- 
tats are taken, and whole body selenium analyses are conducted 
on the pooled samples. 

San Joaquin Kit Fox . More than 2 5 confirmed 
sightings of kit fox have been made at Kesterson NWR and vicin- 
ity, but it is currently unknown how many individuals frequent 
the area or to what extent they are at risk of contamination. 
The USFWS has submitted a proposal to the USBR for a 4-year 
study to examine these questions (Paveglio pers . comm.). This 
study includes night spotlighting surveys, den surveys, radio- 
telemetry, and selenium (and other trace elements) analyses of 
blood and hair samples. The USBR has partially funded this 
project. 

Synoptic Surveys 

Objective . The primary objective of the synoptic 
surveys (e.g., collecting many samples over a large area) is to 
refine the direction and scope of the initial monitoring pro- 
gram. A second objective is to ensure that the UCB/LBL data are 
representative of conditions throughout Kesterson Reservoir. 

Approach . The synoptic surveys will be conducted 
during the fall of 1986 and spring of 1987. Initial inspection 
of the UCB/LBL data suggest that more samples will be needed 
from upland habitats in the northern ponds, and from shallow 
water wetlands throughout Kesterson Reservoir. A detailed work 
plan for the synoptic surveys will be developed, in coordination 
with USFWS, by early fall 1986; initial concepts are presented 
below. 

Habitat Classification . A review of the four habitat 
types at Kesterson Reservoir described by Wallenstrom (pers. 
comm.), and used by Home (1986), suggests that it would be 
desirable to incorporate vegetation types (as described in the 
Draft EIS) in addition to hydrological regimes. The system used 
by Home (1986) provides the basis for a topographical-hydrolog- 
ical classification of physical habitats; however, clarification 
was needed as to the relationship between these physical habitat 



2-16 



types and vegetation cover types. The relationship between 
these two should be unambiguous in most parts of Kesterson 
Reservoir, because plant cover types are usually sensitive 
indicators of long-term hydrological conditions in wetlands. A 
preliminary revised classification addressing these consider- 
ations is presented below. Refinements of the classification 
scheme can be made in consultation with the USFWS and UCB/LBL. 

Table 2-4 indicates the occurrence of each habitat type in 
the ponds at Kesterson Reservoir. These habitat types are: 

1) Permanently inundated with deep water 

a. unvegetated open water containing only planktonic 
plants 

b. submergent vegetation dominated by Nitella 

c. emergent vegetation dominated by Typha 

2) Usually inundated with shallow to moderately deep water 

a. emergent vegetation dominated by Scirpus maritimus 

b. emergent vegetation dominated by Typha 

c. submergent vegetation dominated by Nitella , 
bluegreen, or other algae 

3) Seasonally inundated with shallow water 

a. unvegetated, or more often with filamentous algae 
and/or rooted submergents such as Zannichellia or 
Ruppia 

b. nonemergent vegetation dominated by Cressa and/or 
Sida 

4) Seasonally wet soils, but rarely inundated 

a. nonemergent vegetation dominated by Distichlis and 
Frankenia 

b. remnant patches of upland vegetation on ridges and 
mounds, characterized by Atriplex patula , Sporoblus , 
or Allenrolfea 

The hydrological regimes listed as items 1-4 above are best 
indicated by the plant species which are dominant or most vigor- 
ous in a given locality. Distichlis , for example, is abundant 
in areas that have seasonally wet soils, but are rarely inun- 
dated. Distichlis may occur among seasonally inundated Scirpus , 
but in less abundance and with less vigor. Similarly, Typha is 
most abundant and vigorous in areas of permanent inundation, but 
may occur with less vigor in sites with less water. 

Sample Design and Data Analysis . Table 2-5 summarizes 
the major taxa and trophic levels proposed for sampling under 
the synoptic surveys. Each organism will be sampled five times 
in a single habitat (e.g., for Typha , either Ic or 2b) at each 
of approximately six ponds, for an approximate total of 30 
samples for the entire Reservoir. Sampling points used during 

2-17 



Table 2-4. Habitat Types at Kesterson Reservoir 



Pond Number Habitat Type 

1 la, Ic, 2a*, 2b 

2 la, Ic, 2a, 2b 

3 la, Ic, 2a, 2b, 2c* 

4 la, Ic, 2a, 2b, 2c* 

5 la, lb, Ic, 2a, 2b, 2c 

6 2a, 2b, 3a, 3b, 4a 

7 2a, 2b, 3a, 3b, 4a, 4b* 

8 2b*, 3a, 3b, 4a, 4b* 

9 3a, 3b, 4a, 4b* 

10 3a, 3b, 4a, 4b* 

11 3a, 3b, 4a, 4b* 

12 3a, 3b, 4a, 4b* 



Notes : 

Habitat types present at initiation of FRP, before discing of the dry 
areas of the northern ponds. 

See text for a description of habitats. 

Asterisks (*) indicate habitats of lijnited ocomrence. 



2-18 



Table 2-5. Proposed Sanpling Areas and Sairpling Intensity 
for the Synoptic Surveys 



Taxononic Group 


Habitats^ 


Ponds 




Total 
Sanples 


Plankton 


la 


1-5 


30 


tows 


Plants 
Typha 


Ic, 2b 


1-5, 7 


30 saitples 
(15 g wet wt) 


Scirpus 


2a 


3, 4, 6, 7 


30 saitples 
(15 g wet wt) 


Distichlis 


4a 


6, 8-12 


30 sanples 
(15 g wet wt) 


Cressa 


3b 


6, 8-12 


30 sanples 
(15 g wet wt) 


Epi flora 


la,c, 3a 


1-5, 7 


30 sanples 
(15 g wet wt) 


Epi fauna 


lb,c, 2c, 3a 


1-5, 7 


30 
(5 


sanples 
g wet wt) 


Benthic 

Invertebrates 


la,b,c, 2a,b,c 


1-5, 7 


30 
(5 


sanples 
g wet wt) 


Surface-dwelling 
Invertebrates 


la,b, 2a, c 


1-5, 7 


30 
(5 


sanples 
g wet wt) 


Fish 


la,b, 2b, c 


1-5, 7 


30 
(5 


sanples 
g wet wt) 


Birds 

American coot 


la,b,c, 2a,b,c 


1-5, 7 


30 
(5 


sanples 
g wet wt) 


Red-winged 
blackbird 


Ic, 2b, 4b 


1-5, 7, 12 


30 
(5 


sanples 
g wet wt) 


Maimials 

Microtus 


3b, 4a,b 


6, 8-12 


30 
(5 


sanples 
g wet wt) 


Sorex 


3b, 4a,b 
defined in the text. 


6, 8-12 


30 
(5 


sanples 
g wet wt) 


Habitat types are 





2-19 



the initial vegetation surveys conducted for the Draft EIS will 
be categorized according to the vegetation scheme described 
above; five individual sampling points will be randomly selected 
from the total available at each pond sampled. These points 
will be permanently marked so that they can be relocated during 
the second synoptic survey. As indicated in Table 2-5, most 
taxa will only be sampled at either wet ponds (1-5, 7) or dry 
ponds ( 6 , 8-12 ) . 

Lowe (pers, comm.) recommends plant biomass of at least 
15 g wet weight, and animal samples of at least 5 g wet weight 
for two-way split sample selenium analyses. All samples will be 
analyzed for their selenium content; at least 15 percent of the 
samples will be sent to a second laboratory for independent 
analysis. 

Data collected during the synoptic sampling program (30 to- 
tal samples per taxa from at least six ponds) will be analyzed 
using paired t-tests and with the analysis of variance (ANOVA) . 

Sample Methods . The synoptic surveys will incorporate 
many of the organisms and methods of the UCB/LBL studies (Home 
1986), but they will also sample additional taxa as described 
below. Taxonomic groups, habitats, and sample ponds are sum- 
marized in Table 2-5. 

Plankton . In open water portions of each of the wet 
ponds, five plankton collections (at least 5 g per sample) will 
be made according to the methods of Home (1986) . A total of 
30 plankton samples will be collected during each synoptic 
survey . 

Plants . Plant material constitutes by far the great- 
est biomass at Kesterson Reservoir. Above-ground plant parts 
(stems, foliage, and seeds) will be collected and analyzed 
separately from below-ground parts (roots and rhizomes) for each 
species. At each pond, five samples (at least 15 g per sample) 
will be collected for each of the indicator species discussed 
under wet and dry treatments below. All plant samples will be 
placed in individually numbered plastic bags and frozen before 
and during transportation to the laboratory. 

Wet Ponds . The results of the previous 
vegetation surveys (described in the Draft EIS) suggest that 
cattails ( Typha spp.) are widespread in all the ponds proposed 
for the wet treatments (Ponds 1-5, 7) and will be a suitable 
indicator species. Alkali bulrush ( Scirpus maritimus var. 
paludosus ) , an important wildlife food plant, will also be a 
suitable indicator species. 

Dry Ponds . The previous vegetation surveys 
(see Draft EIS) also suggested that saltgrass ( Distichlis 
spicata ) and alkali weed ( Cressa truxillensis ) are widespread in 



2-20 



all the northern ponds and will be good indicator species for 
the dry-treatment ponds (Ponds 6, 8-12). 

Epiflora and Epifauna . Diatoms and filamentous 
algae will be collected from areas of submergent vegetation at 
each of the wet ponds according to the methods of Home (1986) . 
Five samples (at least 15 g wet weight) will be collected from 
each pond. 

Epifaunal organisms will be represented by the larvae of 
damselflies and chironomids; these will be collected by the 
methods described by Home (1986) . A total of 30 damselfly and 
30 chironomid samples will be collected from the six wet ponds. 

Benthos . The benthic community will be repre- 
sented by the larvae of soldier flies and ostracods which, along 
with chironomids and bacteria, provide detrital food pathways at 
Kesterson Reservoir. Five soldier fly, crane fly, benthic 
chironomid, and ostracod samples (at least 5 g wet weight) will 
be collected from each pond according to the methods of Home 
(1986) . 

Surface-Dwelling Invertebrates . Corixids and 
notonectids (including both adult and larval forms) will be 
captured by dip net samples at five sampling stations in the 
aquatic habitats of each pond as indicated in Table 2-5. 

Fish . Five Gambusia samples (at least 5 g wet 
weight) will be collected from each of the wet ponds for whole- 
body analyses of selenium content. Dip net sampling will be 
used, as described by Home (1986) . 

Birds . It is difficult to correlate reductions 
in selenium levels of specific ponds with concentrations meas- 
ured in individual birds due to the high mobility of waterfowl 
and other species. Resident or breeding birds will be the best 
indicator species because they frequent Kesterson Reservoir on a 
regular basis. Potential species for analysis include: Ameri- 
can coot in the wet ponds and red-winged blackbird in the dry 
ponds. Liver and whole-body analyses will be conducted for 
these indicator species; a total of 30 samples (5 g wet weight) 
will be needed for each species. The current policy of collect- 
ing dead birds found at Kesterson Reservoir for analysis will be 
continued. 

A second portion of the synoptic monitoring program for 
birds will be a continuation of the nesting studies initiated in 
1983 by Dr. Ohlendorf. During the spring survey, nest obser- 
vations will be made of waterfowl and waterbirds (coots, black- 
necked stilts, and American avocets) to determine if these 
species are continuing to experience nestling mortalities and 
deformities. At least 30 waterfowl and waterbird nests will be 
monitored during the 1987 breeding season to determine the fate 
of their young. 



2-21 



The monitoring studies of tricolored blackbird nests at 
Kesterson Reservoir initiated in 1986 will also be continued in 
1987. These studies will include searches of levee roads around 
Ponds 2 and 5 for evidence of chick mortalities. The breeding 
colony will also be searched to determine the success of indivi- 
dual nests. These studies may include observations at a control 
site at either San Luis or Merced NWR. Observations will be 
continued until the young have fledged to determine the overall 
success of the colony. 

Mammals . Small mammals will be collected in 
selected portions of the dry ponds and at the margins of wet 
ponds. Both herbivores and carnivores will be examined to 
facilitate comparisons between trophic levels, Sherman live 
traps will be set along transects and spaced at 5-10 m intervals 
in appropriate nonemergent and upland vegetation. Approximately 
30 pooled liver samples (5 g wet weight) will be collected for 
each species. Because it is possible that small mammals are 
feeding at Kesterson Reservoir and moving offsite, additional 
trapping transects will be set at various intervals (e.g., 0.25, 
0.5, and 1 km) from the outside levee margins to determine if 
these populations are also contaminated. 

Refinement of the Monitoring Plan . Based upon the UCB/LBL 
initial monitoring program, the synoptic surveys, and continued 
input from the USFWS , the USER expects to have a refined moni- 
toring program developed by the summer of 1987. 



Groundwater Monitoring Program 

Objective . The objectives of the post-closure groundwater 
monitoring program at Kesterson Reservoir are to detect offsite 
contamination (selenium); initiate an evaluation of the data if 
selenium concentrations exceed 10 ug/1, the EPA drinking water 
standard, at predefined point of compliance wells; and initiate 
interim remedial measures, if required. The 10 pg/1 standard is 
currently under review by EPA. If EPA modifies this standard, 
USER will consider modifying the threshold for groundwater 
monitoring purposes. 

Responsibility . The USER is responsible for implementing 
the post-closure monitoring program. 

Extent of Contamination . The present extent and future 
potential for groundwater contamination at Kesterson Reservoir 
is a major concern in the cleanup strategy. Of the more than 
200 wells sampled at Kesterson Reservoir, about a dozen have 
selenium concentrations which exceed the EPA drinking water 
standard of 10 ug/1. These wells are generally located either 
adjacent to Ponds 1, 2, 3, 4, and 5 in the southeast portion of 
the Reservoir, or near Ponds 11 and 12 in the northern Reser- 
voir. Extensive offsite sampling in the Kesterson NWR to the 
northeast of the ponds revealed no selenium contamination (LBL 



2-22 



1985) . However, recent sampling immediately east of the SLD 
along Ponds 1 and 2 has shown elevated selenium concentrations. 

The selenium plume, arbitrarily defined as groundwater' 
containing >10 yg/1 total selenium, is limited to a 600-foct- 
wide zone near the intersection of the levee roads between Ponds 
2, 3, and 4 (Figure 2-3). The eastern extent of this plume is 
undefined because landowners have prohibited the installation of 
monitoring wells in this, the regional downgradient , direction. 
See discussion on point of compliance wells below. 

Detection 

Well Locations . The groundwater monitoring program 
does not include unsaturated zone monitoring because water 
levels fluctuate seasonally from 8 feet below to 1-2 feet above 
ground surface. 

Recommended monitoring well locations for the FRP are shown 
in Figure 2-4. The locations of these wells were chosen to 1) 
detect the off site migration of selenium, 2) provide background 
water quality data, and 3) provide sufficient data to evaluate 
the long-term impacts of the cleanup alternative. 

The monitoring network consists of two well sets aligned 
parallel to the regional groundwater flow direction. Well Set 
No. 1 is placed to evaluate the movement of selenium beneath the 
southern ponds where selenium has migrated into the groundwater. 
Under the FRP, these ponds will be flooded. Well Set No. 2 is 
placed to evaluate the movement of selenium beneath the northern 
ponds. 

The shallow wells northeast of the Reservoir are located to 
detect the offsite migration of selenium. The first line of 
shallow wells in each well set is located roughly 150 feet 
northeast of the Reservoir. A second line of shallow wells is 
located approximately 400 feet northeast of the Reservoir. The 
downgradient distances to these wells were chosen to provide 
useful information consistent with a quarterly monitoring sched- 
ule. 

The background water quality wells for each well set are 
located approximately 0.25 mile southwest of the Reservoir 
(upgradient) and 0.25 mile northeast of the Reservoir (downgra- 
dient) . Two wells (one shallow and one deep) are included at 
each location. 

In addition to these wells, six wells in each well set 
(three shallow and three deep) are located along the eastern 
perimeter of the Reservoir. These wells, along with the two 
wells near the intersection of Ponds 2, 3, and 4 in Well Set 
No. 1, will provide the data required to evaluate the long-term 
impacts of any offsite contamination. 



2-23 



Ri 




MAXIMUM SELENIUM CONCENTRATIONS 
RECORDED BETWEEN 5/85 AND 11/85 
AT WELLS OR WELL NEST (/«g/l) 

AN UNDERLINE DENOTES A SITE SAMPLED 

FOR SELENATE BY LAWRENCE BERKELEY LABORATORY 

SOURCE: USBR 1985a 
LBL 1986 



FIGURE 2-3 

KESTERSON RESERVOIR 
SHALLOW GROUNDWATER 
SELENIUM CONCENTRATIONS 




1 MILE 



WELL LOCATIONS 
NOT TO SCALE 



LEGEND 



DRY POND (NO WATER APPLIED) 



^<:^^ WET POND (APPLIED WATER) 

A WELL CLUSTER (1 SHALLOW, 1 DEEP) 
• SHALLOW WELL 



FIGURE 2-4 

WELL LOCATIONS 
POST-CLOSURE 
MONITORING PROGRAM 
KESTERSON RESERVOIR 

2-25 



Constituents . A preliminary list of constituents to 
be monitor"ed is presented in Table 2-6. The constituents are 
divided into three parameter sets: Set A is a full suite of 
analyses, Set B is a reduced suite of analyses, and Set C con- 
sists of field analyses. The sampling schedule for parameter 
Sets A and B is described in the following section. 

Water level measurements will be taken at each well prior 
to sampling, and the USER will record the water levels in at 
least 30 additional wells on a quarterly schedule. 

Scheduling . Scheduling for the first year of ground- 
water monitoring is outlined in Table 2-7. In general, all the 
wells will be sampled monthly for the first quarter and quarter- 
ly thereafter. The monthly schedule is required to evaluate the 
monitoring network and to provide a framework against which 
subsequent analyses will be compared. 

Data Evaluation . If the total selenium concentration 
exceeds TO ug/1 in either point of compliance well (see Fig- 
ure 2-4) , the data will be evaluated to determine whether the 
increasing levels have resulted from the failure of the remedial 
action. After this evaluation, the monitoring program will be 
revised and/or interim remedial measures taken to protect the 
groundwater. 

Interim Remedial Measures . Localized pumping along the 
eastern perimeter of the Reservoir will be instituted if interim 
remedial measures are required. 

These wells will be designed to extract water from the con- 
taminated portions of the aquifer. This water wil'l be blended 
in the drain with the groundwater already being applied to the 
Reservoir. If the selenium concentration in this blended water 
exceeds 5 ug/l, the extracted water will not be blended, but 
will be applied to Pond 7. Intensive hazing and physical barri- 
ers, if required, will be instituted to inhibit waterfowl from 
using this pond. 

The extraction well pumping rates will be adjusted to 
create a gradient reversal, as determined by measuring water 
levels in existing wells, and to provide sufficient water to 
meet the requirements for maintaining the water levels and water 
quality goals for the Reservoir. 

Air Quality Monitoring Program 

Objective . The objective of the air quality monitoring 
program is to collect ambient selenium data in a manner consis- 
tent with EPA and state policies for collection of such data and 
to analyze the data in a similarly proficient manner. As such, 
the ambient levels of selenium will be measured in the area 
about Kesterson Reservoir before, during, and after various 



2-26 



Table 2-6. Preliminary GrouncSwater Analyses Parameter Sets for Post-Closure 
Monitoring Program at Kesterson Reservoir 



Constituent 



Calcium 

Magnesium 

Potassium 

Sodiimi 

Bicarbonate 

Giloride 

Nitrate 

Phosphate 

Sulfate 

Arsenic 

Boron 

Chratuum (total) 

Copper 

Molybdenum 

Iron (total) 

Iron (ferrous) 

Nickel 

Selenium (total) 

Se lenium ( se lenate ) 

Dissolved oxygen 

EC X 

pH X 

Eh X 

Tenperature X 



Parameter 


Parameter 


Parameter 


Set A 


Set B 


Set C 


X 






X 






X 






X 






X 






X 






X 






X 






X 






X 






X 


X 




X 






X 






X 






X 


X 




X 


X 




X 






X 


X 




X 


X 




X 


X 


X 



Notes: Parameter Sets A and B are for laboratory analyses; see Table 2- 
for scheduling of these Peurameter Sets. Paranieter Set C is for 
field analyses. 



2-27 



i 



Table 2-7. Groundwater Monitoring Schedule 
for Post-Closure Monitoring Program 
at Kesterson Reservoir 



Background Onsite Offsite 

Month (8 wells) (14 wells) (14 wells) 



1 A A A 

2 B B B 

3 B B B 

4 A A A 
5 

6 

7 A A B 

8 

9 
10 A A B 

11 
12 

1 A A B 



Notes: A - Laboratory einalyses by Parameter Get A. 
B = Laboratory analyses by Parameter Set B. 
Field analyses (Parameter Set C) will precede all sampling. 



2-28 



phases of contaminant cleanup. The monitoring program will be 
the same regardless of the cleanup plan selected. 

Approach . The approach will be to collect particulate 
samples per standard EPA guidance and procedures on a routine 
sampling schedule and to analyze for particulate selenium by 
atomic absorption. The samplers will be located in such a way 
as to surround the site and measure concentration levels regard- 
less of the wind conditions. To aid in interpretation of the 
results, a meteorological station will be appropriately sited 
and operated in conjunction with the particulate samplers. 

Methods . The sampling network will consist of three PM-10 
sampling stations operated every sixth day in conjunction with 
the National Particulate Sampling Schedule, or once per month 
based on the frequency of violations. A meteorological station 
will be operated at one of the stations. 

Sampling Locations . The three monitoring sites will 
surround the Reservoir area. Site 1 will be north of Pond 12. 
This site will be upwind of the Reservoir during periods of 
northwesterly winds. Site 2 will be on Gun Club Road on the 
eastern boundary of the zone. This site has been used for past 
sampling and will provide data for consistency comparisons. 
This is also the site closest to the nearest residences. It 
will be the site of the meteorological station. Site 3 will be 
south of Pond 1. This site will be downwind during periods of 
northwesterly v^7inds and upwind during periods of southwesterly 
winds . 

Power will be required for all three sites. New overhead 
lines through Kesterson NWR will not be required to supply this 
power. 

Number and Frequency of Sampling . Samples will be 
collected every sixth day from the three sites or once per month 
based on the frequency of violations. Additionally, one of the 
sites will have colocated samplers as required by the U. S. 
Environmental Protection Agency (EPA) for quality assurance. A 
total of four samples every sixth day or 20 samples per month 
will be collected. Meteorological data will be collected con- 
tinuously. 

Constituents to be Analyzed . From the samples col- 
lected, particulates and selenium content will be determined. 
These concentrations will be based on total flow of the samplers 
and the concentrations found on the filters. 

Sampling Collection, Handling, and Storage . Particu- 
late filter samples will be collected every sixth day or once 
per month based on the frequency of violations and forwarded to 
an approved laboratory for analysis. Filters will be preweighed 
at the laboratory, installed, removed, and transferred in accor- 
dance v;ith procedures outlined in EPA's Quality Assurance 



2-29 



Handbook. The meteorological data will be stored on cassette 
tape and then transferred to a microcomputer. 

Data Analysis . Data analysis for the particulate and 
selenium concentrations will be based on the sampled mass of 
material analyzed and calculated to a mass/volume of air concen- 
tration based on a known air flow rate and sampling time. 
Meteorological correlations will not be made unless high con- 
centrd-tions of selenium are discovered. The filters will be 
analyzed monthly, and a report will be made including the month- 
ly concentrations and a monthly wind rose summary. 

Surface Water Monitoring Program 

O bjectives . Surface water near Kesterson Reservoir will be 
monitored to assess the impacts from the Reservoir on the water 
quality of surrounding water bodies. Kesterson Reservoir ponds 
will be monitored to determine if mobilization of the contami- 
nants from the sediments has occurred, and to measure the con- 
stituents in the SLD water as it moves into and through the 
Reservoir . 

The selenium concentration goal for Kesterson Reservoir 
surface water is 5 pg/1 for protection of fish and wildlife. 
This goal is higher than the 2 pg/1 recommended by USFWS; see 
discussion of FRP risks in Chapter 3 of the Final EIS for the 
rationale for selecting 5 ug/1. 

Flow measurements will be made in Mud Slough upstream and 
downstream of Kesterson Reservoir and on the two canals dis- 
charging into Mud Slough in this area, Fremont Canal and Santa 
Fe Canal. Flow measurements combined with selenium concentra- 
tions will give a selenium miass balance for Mud Slough as it 
passes Kesterson Reservoir. 

Monitoring Site Locations . Eleven monitoring sites will be 
located upstream and downstream from Kesterson Reservoir on 
canals and sloughs that flow adjacent to the Reservoir. Within 
Kesterson Reservoir, water quality will be measured at six weir 
structures between the southern ponds, in the northwestern 
corners of Ponds 4 and 7, and at the SLD inflow point in Pond 2 
(Table 2-8) . 

Field Sampling . Samples will be collected monthly. Proce- 
dures for sample collection, storage, and transfer will be 
analogous to those used for groundwater sampling. Constituents 
to be measured in the field and in the laboratory are the same 
as those for groundwater listed in Table 2-6. 



Public Health Monitoring Proqr 



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2-30 



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2-31 



levels of workers and residents in the Kesterson Reservoir and 
SLD vicinity since inid-1984. Approximately 125 persons have 
been tested for baseline selenium levels. Although testing 
analysis techniques have been variable, considerable baseline 
data has been accumulated. To date, no subjects tested have 
exceeded normal levels. 

Future monitoring will be conducted during the Reservoir 
cleanup activities to assess health effects. 

Populations to be Monitored 

o Agency and construction personnel working within the 
Kesterson Reservoir or SLD area. 

o Residents living within 1 mile of the Reservoir area as 
agreeable. 

o People who use the Reservoir or SLD areas. 

Monitoring Activities 

o Agency personnel and workers who have risk of exposure 
to contaminants at Kesterson Reservoir or SLD for 30 
cumulative days within a 6-month period. Conduct whole 
blood and 24- hour urine and hair sample analyses at 
6-month intervals. Testing techniques described here 
and below are currently under review. Modifications may 
result from recommendations made by the Public Health 
Subcommittee of the SJVDP. 

o Require a medical history, whole-blood or serum enzyme 
activities, and hair sample of all personnel newly 
assigned to work within the Reservoir area (including 
construction workers involved in cleanup efforts) . 
Conduct exposure analyses semi-annually upon persons 
with 30 days cumulative exposure during the 6-month 
period. 

o Require that persons with risk of exposure to contami- 
nants follow safety procedures as outlined by the USER 
Regional Safety Office while working in the Reservoir or 
SLD area, to minimize personal contact with contami- 
nants . 

o Coordinate with the Merced County Health Department to 
conduct whole-blood, 24-hour urine, and hair sample 
analyses every 6 months upon individuals with frequent 
exposure to Kesterson Reservoir or the SLD. 

o Design and implement a public education and information 
program to warn people who may use the Reservoir and/ or 
SLD area of the potential hazard of consuming foods with 
high selenium content. 



2-32 



o Continue research and efforts to identify other contami- 
nants that might pose a potential hazard and to identify 
threshold levels for exposure. 



Immobilization Plan 



General Description 

The Immobilization Plan will generally be an extension of 
the FRP but with additional procedures taken to minimize seleni- 
um mobility. Even with the implementation of these additional 
procedures, some scientists and commenters on the Draft EIS 
believe that existing literature and research strongly suggest 
that the Immobilization Plan will clearly fail, and that risks 
to fish and wildlife associated with the plan are unacceptable. 
These issues are discussed in detail in the review of FRP im- 
pacts in Chapter 3 of this Final EIS. 

Southern Ponds . During the implementation of the FRP, 
management procedures for the Immobilization Plan will be tested 
in Pond 4. Immobilization Plan effectiveness will be evaluated 
before it will be implemented. 

Under the Immobilization Plan, emergent vegetation in the 
southern ponds (1-5 and 7) will be harvested (using wet harvest- 
ing techniques), and disposed at an approved disposal site. 
Water will then continue to be applied, but water levels will be 
greater, generally within 0.5 feet of the design maximum normal 
water surface elevation, as shown in Table 2-1. 

Northern Ponds . Discing to eliminate vegetation will be 
tested, and if successful, will be implemented in the spring 
over the entire dry area of the northern ponds (see FRP) . It 
discing is not successful in preventing food chain contamina- 
tion, then vegetation will be harvested in dry areas. Vege- 
tation in the dry areas will be harvested and baled using stan- 
dard agricultural equipment. The vegetation will be trucked to 
an approved disposal site. Mechanical loading equipment will be 
used to load and unload the trucks. Vegetation harvesting will 
be completed in late spring, and will be continued if new vege- 
tation continues to have selenium concentrations greater than 
3 mg/kg. 

If the FRP results in continued contamination of seasonal 
wetlands in the northern ponds, the seasonal wetlands will be 
disced (if testing shows this to be effective) , harvested, or 
filled and compacted to match the average elevation of the 
ponds. If filled, a clayey material from commercial offsite 
sources will be used as the fill source. An average fill depth 
of 1 foot would be placed over a maximum of 230 acres of season- 
al wetlands (the remaining 380 acres of the northern ponds will 
be upland habitat under the Immobilization Plan) . 



2-33 



Water Supply 

The water supply for the Immobilization Plan will be from 
the same shallow wells described earlier in the FRP . A minor 
increase of less than 5 percent water volume will be needed 
because of slightly greater evaporation and infiltration. 



Operation 

The operation of the Immobilization Plan, as described 
above, is dependent on data collected during the FRP. The 
southern ponds will be maintained with deep water. The northern 
ponds will be operated to remain as dry as possible, and will 
have very limited vegetative growth. (See General Description 
above. ) 

Nuisance Abatement Program (Short-Term Mitigation) 

The goal of the Immobilization Plan nuisance abatement 
program is to reduce exposure of fish and wildlife resources to 
residual contamination at Kesterson Reservoir during the cleanup 
process, or to compensate for any continuing exposure that is 
not avoided. Nuisance abatement activities will be similar to 
those discussed for the FRP, and will continue as long as selen- 
ium concentration goals in biota are not being achieved. 



Land Use 

The wet ponds will provide deep water habitat, and the 
northern ponds will provide upland or seasonal wetland habitat. 
Public access will be restricted. 



Mitigation 

As discussed under the FRP, two categories of wetland 
mitigation actions are being considered: short-term (or nuisance 
abatement) and long-term. Specific actions now under consider- 
ation, decisionmaking factors, and USFWS mitigation recommenda- 
tions are similar to those discussed under the FRP. 



Biota Monitoring Program 

As part of the FRP, Pond 4 will be filled to a deeper level 
than the other wet ponds as a preliminary test of the Immobili- 
zation Plan. The FRP monitoring plan for this pond will be the 
same as for all the other wet ponds. If Pond 4 achieves selen- 
ium reduction goals within 1-5 years, the monitoring program 
will be streamlined, in consultation with USFWS, to include only 
certain ponds and selected indicator taxa. Biological monitor- 
ing will continue in the dry ponds as in the FRP. 

2-34 



Groundwater Monitoring Program 

Groundwater monitoring goals and scope will be the same as 
described in the FRP . 



Air Quality Monitoring Program 

Air quality monitoring goals and scope will be the same as 
described in the FRP. 



Surface Water Monitoring Program 

Surface water monitoring goals and scope will be the same 
as described in the FRP. 



Public Health Monitoring Program 

Public health monitoring goals and scope will be the same 
as described in the FRP. 



Onsite Disposal Plan 



General Description 

The Onsite Disposal Plan consists of excavating all sedi- 
ments and soil (and associated vegetation) with selenium concen- 
trations y_A mg/kg; dry harvesting all remaining above-ground 
vegetation; and depositing the material in an onsite landfill 
enclosed with a PVC synthetic membrane or similar material of 
extremely low permeability. The estimated volume of contaminat- 
ed material (sediments and vegetation) is 450,000 cubic yards 
based on existing sediment and vegetation sampling information. 
Additional sediment sampling may be done before construction to 
better define the selenium distribution and resulting required 
excavation, if ongoing analysis indicates this is necessary. 
The landfill site will encompass about 30 acres, assuming an 
average thickness of 9 feet. 

A number of refinements were made to the Onsite Disposal 
Plan in response to comments on the Draft EIS. Most important- 
ly, because of concerns expressed regarding possible contamina- 
tion of restored wetlands from residual contaminants following 
excavation, no active attempt will be made to restore Kesterson 
Reservoir to its baseline habitat values through provision of a 
water supply. Without adding water to the Reservoir, about 
780 acres of the Reservoir will become upland habitat, about 40 
acres of Pond 3 will be used for the onsite landfill and buffer 
area, and about 420 acres will be seasonal wetlands. 



2-35 



The western half of Pond 3 was selected for the disposal 
site, instead of Pond 8 as originally proposed, for several rea- 
sons. The preconstruction thickness of the surficial clayey 
soil is similar in both ponds. The ground elevation of the 
western half of Pond 3 ranges from 74 to 75 feet MSL, which is 
about 1 foot higher than Pond 8. The 25-year high groundwater 
elevation in the area of Pond 3 is expected to be 75.0 feet MSL. 
Water levels may not rise to this elevation because of the low 
permeability clayey soil beneath the landfill site. Only a 
small area of the existing western half of Pond 3 has land 
surface below this elevation. The landfill site will be filled 
in order to achieve a lowest bottom elevation of 75.0 feet MSL. 
(Evaluations of filling up to 80.0 feet MSL are currently being 
made.) Siting the disposal area above the expected groundwater 
level will greatly reduce the potential of groundwater entering 
the landfill. The additional fill material will be compacted to 
low permeability (£1 x 10 cm/sec) , which will further reduce 
water movement into or out of the landfill. 

Finally, the western half of Pond 3 is more centrally 
located to those areas of Kesterson Reservoir which will require 
the most soil removal. Areas shown in Figure 2-5 with selenium 
concentrations >^4 mg/kg will have 6 inches of surface soils 
removed. The Pond 3 landfill location will decrease haul dis- 
tance and increase the efficiency of landfill construction 
implementation. 

Since the soil and vegetation are assumed to be designated 
waste for purposes of this EIS, the requirements for a Class II 
landfill would be used to design, construct, and monitor the 
proposed landfill. The requirements for a Class II landfill are 
contained in the California Administrative Code, Title 23, 
Subchapter 15. 



Landfill Construction 

The Onsite Disposal Plan could be implemented at any time, 
the earliest being in March 1987. Assuming a March 1, 1987 
decision to implement, dewatering and landfill construction 
could be completed by February 5, 19 88. 

A construction scenario is presented below as an example of 
equipment needs and the construction sequencing needed to com- 
plete the landfill. The information presented should be con- 
sidered general in nature; specific components will be revised 
as plans and specifications are finalized. 

Starting on March 1 , no water would be applied to Kesterson 
Reservoir. The volume of water in Ponds 1-5 and 7 would be 
about 1,750 acre-feet. The next step would be to completely 
drain Pond 3 by pumping to adjacent ponds. 



2-36 







CD 



>4 mg/kg SELENIUM 



10 mg/kg CONTOUR 
>15 mg/kg SELENIUM 



FIGURE 2-5 

KESTERSON RESERVOIR 

SOIL SELENIUM LEVELS 



2-37 



Ponds 6 and 8-12 may have some water in depression areas as 
a result of heavy rainfall or rising groundwater. These areas 
would be drained by gravity or pumping. 

Construction would begin approximately May 1 , assuming 
Ponds 3 and 8 are sufficiently dry to support construction 
equipment. An example of construction sequencing follows: 

o Remove contaminated soil and vegetation from Pond 8 and 
the western half of Pond 3. Stockpile the waste mater- 
ial in the eastern half of Pond 3. 

o Haul clayey soil from Pond 8 to Pond 3 and construct the 
landfill base to elevation 75 feet MSL. Construct 
grades to provide leachate drainage. 

o Install liner and leachate filter material. 

o Remove vegetation and soil from Ponds 9, 11, 12, 10, and 
6 to landfill. Cleaning the ponds in this order will 
allow any remaining water to drain from Ponds 1, 2, 4, 
5, and 7 into the northern ponds for infiltration and 
evaporation. The SLD may also be used if necessary to 
store remaining water and allow cleaning of the southern 
ponds . 

o Haul contam.inated soil and vegetation (including stock- 
piled material) from eastern half of Pond 3 into land- 
fill. This provides time for the southern ponds to dry 
out. 

o Haul contaminated material from Ponds 1, 2, 4, 5, and 7 
to landfill. 

o Install top synthetic liner and cover soil over land- 
fill. Complete leachate collection system, and plant 
grass cover. 

The contaminated soil and vegetation will be placed in 
1-foot lifts and compacted to at least 85 percent relative 
compaction. The contaminated soil hauling will continue 
throughout the spring, summer, and fall months until the contam.- 
inated material is placed in the landfill. 

The slopes and top of the fill will be trimmed neat and 
completely covered with a synthetic membrane. The membrane will 
be covered with a minimum of 2 feet of onsite soil. The entire 
area will be reseeded and a stand of natural grass established. 
Temporary irrigation will be used to establish the vegetative 
cover. The grass will be shallow-rooted and provide erosion 
control. The final slopes will be 3 percent to provide adequate 
runoff. A typical cross-section of the landfill is shown in 
Figure 2-6. 

The existing embankments on the north, west, and south 
sides of the landfill site will be incorporated into the buffer 
zone of the landfill. Additional compacted clayey material 
excavated from Pond 8 will be placed along the inside of the 
existing embankment to widen the surrounding embankment of the 
landfill and decrease the potential for surface water movement 



2-38 




2-39 



through the embankment. The proposed eastern embankment will be 
constructed on a homogeneous dike made of clayey soil from the 
Pond 8 borrow area. The top of the embankment will be about 
20-25 feet wide, which will provide room for a fence, a drainage 
ditch, and a road for vehicle access. The 6-foot-high chain- 
link fence with gates will surround the landfill and eliminate 
casual vehicular and foot traffic. The drainage ditch will be a 
small graded swale designed to discharge surface runoff to 
Pond 4. Public access will not be provided. The road will be 
used tor operation and maintenance personnel. 

The existing clay soil in Pond 3 has low permeability and 
will provide a measure of security to the landfill. Perme- 
ability is currently being evaluated as part of ongoing investi- 
gations. Piezometers placed around and within the area beneath 
the landfill will provide information on the hydrostatic pres- 
sure at the base of the landfill and the potential for ground- 
water infiltration into the landfill. Four-inch wells will be 
installed around the landfill to monitor the saturated zone. 

Settlement of the landfill will be evaluated from new 
borings which are scheduled to be placed in the landfill area in 
October 1986. Settlement of the landfill will be evaluated and, 
if the settlement evaluation indicates excessive settlements for 
the proposed bottom liner, the height of the landfill will be 
decreased and the area will be increased. Evaluation of the 
shear strength of the native soils and landfill materials will 
also be performed to provide stable slopes under both static and 
dynamic conditions. 

There are no known seismic faults that cross Pond 3. 
Therefore, the potential for rupture of the landfill is con- 
sidered extremely low. 

The selection of the synthetic membrane is based on the 
desirable qualities of flexibility, resistance to corrosion, and 
ease of construction. A liner of this type can be placed con- 
tinuously during periods of dry weather. The seams are over- 
lapped and continuously bonded, thus providing a continuous 
liner over the landfill area. Based on information provided by 
manufacturers, the synthetic membrane will be compatible with 
the contaminated soils and leachate that may contact it. 

Leachate Collection and Disposal 

Leachate can be produced by infiltration from rainfall or 
rising groundwater. To collect leachate, the base of the land- 
fill under the synthetic liner will be graded to provide three 
drainage subareas that divide the landfill roughly into thirds 
along the north-south axis. Each subarea will be graded at a 
mild slope to a collection manhole at the center of the subarea. 
The leachate will be pumped from each manhole north to a holding 
or treatment facility. 



2-40 



After the final grading of the base has been completed, the 
synthetic membrane will be installed. The synthetic membrane 
material will have a permeability equivalent to 2 feet of mate- 
rial at 1 X 10~ cm/ sec permeability. The membrane will have a 
minimum life expectancy of 20 years. Should the bottom liner 
contain pin holes or deteriorate, the low permeability clayey 
soil under the site will continue to restrict downward leachate 
movement. Leachate will flow to the collection points. The 
site location and synthetic membrane will minimize any ground- 
water entering the landfill. 

Each leachate collection pump station will be equipped with 
a pump with capacity equal to twice the expected maximum flow 
rate. Expected flow is currently being evaluated. Each well 
will be equipped with sensors to monitor leachate elevation and 
pump operation. 

The leachate will be pumped to the north end of the land- 
fill for disposal by one of three possible methods. The dis- 
posal plan will be finalized as a result of review and addition- 
al information concerning quantity and quality of leachate. If 
the leachate volume is very small, a lined holding tank will be 
used to temporarily store the leachate. As the tank fills, the 
leachate will be pumped into a tanker truck and hauled to an 
approved disposal site. The second option is to install a small 
reverse-osmosis treatment plant. Estimates of leachate quality 
are required to design an effective reverse-osmosis package 
plant. Excess brine would be hauled to an approved disposal 
site, and the treated water would be released to Pond 4. The 
third option is to construct an approved small (e.g., 1-acre) 
onsite double-lined evaporation pond. Other contingency mea- 
sures, such as creating a cone of depression underneath the 
landfill, are currently being evaluated. 

Water Supply 

Water will be supplied to the landfill site, if necessary, 
until the grass stand is established. No water will be supplied 
thereafter. 



Operation 

The landfill will have a 20-25 foot buffer and be surround- 
ed with chain-link fencing. No public access will be allowed. 
The fencing will discourage mammal use, but some rodents will be 
present. The 2 feet of cover soil will provide protection to 
the liner for most burrowing animals; any colonies of animals 
will be removed as part of operation and maintenance. 

The surface water drainage facilities for the onsite land- 
fill are sized to convey runoff from a 1,000-year, 24-hour 
rainfall. Runoff will be drained to Pond 4. The 100-year flood 
elevation of the San Joaquin River is expected to be a maximum 



2-41 



of 76 feet MSL in the vicinity of the landfill. The average 
embankment elevation around the landfill is at elevation 80 feet 
MSL or greater; therefore the landfill is protected from both 
local and San Joaquin River flooding. Federal Emergency Manage- 
ment Agency floodplain requirements will be met in the design 
and construction of the landfill. 

Following excavation of "hot spots" and harvesting of 
remaining areas, above-ground stubble and below-ground plant 
parts will remain in those portions of the Reservoir that are 
harvested. To reduce the potential for selenium contamination 
of the food chain from these remaining plant parts, the nonex- 
cavated portions of the Reservoir will be disced following 
harvesting, after evaluating the effectiveness of discing. 
USFWS , in lieu of discing, recommends removal and disposal of 
all remaining vegetation and detritus with selenium concen- 
trations greater than 3 mg/kg. 

Nuisance Abatement Program (Short-Term Mitigation) 

The goal of the Onsite Disposal Plan nuisance abatement 
program is to reduce exposure of fish and wildlife resources to 
residual contamination at Kesterson Reservoir during the cleanup 
process, or to compensate for any continuing exposure that is 
not avoidable. Nuisance abatement activities for the Onsite 
Disposal Plan will be undertaken if selenium concentration goals 
in biota are not being achieved following excavation. Nuisance 
abatement activities will be similar to those discussed for the 
FRP , except that, the entire Reservoir will be monitored follow- 
ing excavation, and further excavation or filling of seasonal 
wetlands will be undertaken for those seasonal wetlands exhibit- 
ing residual contamination. 



Land Use 

Under the Onsite Disposal Plan, the Reservoir will be 
removed from Kesterson NWR because of the incompatibility of a 
landfill with wildlife refuge uses. The Onsite Disposal Plan is 
designed to collect and safely dispose of the contaminated sedi- 
ments and vegetation. The disposal site and the area immed- 
iately around it will have restricted uses but the remaining 
area of Kesterson Reservoir will provide upland and seasonal 
wetlands habitat. 



Mitigation 

As in the FRP, two categories of wetland mitigation actions 
are being considered for the Onsite Disposal Plan: short-term 
(or nuisance abatement) and long-term. Specific actions now 
under consideration, decisionmaking factors, and USFWS mitiga- 
tion recommendations are similar to those discussed under the 
FRP, except that post-excavation nuisance abatement activities 



2-42 



(short-term mitigation) will differ from the FRP, as described 
above. 



Biota Monitoring Program 

The biological monitoring program for the Onsite Disposal 
Plan will focus on detecting residual pockets of selenium con- 
tamination that could remain in the sediments after the cleanup. 

Groundwater Monitoring Program 

It is expected that the areal extent of the groundwater 
monitoring program will consist of several wells near the dis- 
posal site. If contamination is detected in any of these wells, 
monitoring of the more distant wells will be restarted. 

Air Quality Monitoring Program 

Additional air quality monitoring will be done during the 
hauling and construction process. The goals and scope of air 
quality monitoring will otherwise be the same as for the FRP. 

Surface Water Monitoring Program 

Surface water monitoring goals and scope will be the same 
as for the FRP. 



Public Health Monitoring Program 

Public health monitoring goals and scope will be the same 
as for the FRP. 



SLD Management Plan 

USER is proposing to cover the SLD sediments north of 
Manning Avenue with clean water, rather than excavate the SLD 
sediments, based on the following assumptions: 1) selenium can 
be contained in the SLD sediments; 2) application of clean water 
eliminates a primary selenium exposure pathway (surface water); 
and 3) there is a relative lack of vegetation, fish, and wild- 
life resources using the SLD. 

The management and operation of the SLD will be different 
for three reaches of the drain. The reach between Kesterson 
Reservoir and Bass Avenue will be maintained with clean water 
from either the Delta Mendota Canal (DMC) or nearby shallow 
groundwater wells to keep the sediments covered with water and 
protect the structural integrity of the drain. Check structures 
along this reach will be utilized to maintain the water surface 



2-43 



a minimum of 1 foot over the sediments. Sufficient water will 
be added to replace water lost to intiltration and evaporation. 
Sediments along this reach of the drain will not be disturbed. 

The reach ot the SLD between bass Avenue and Manning Avenue 
(farther south) will be managed as described above or will be 
used by Westlands Water District (ViWU) to convey subsurface 
agricultural drainage water to a pilot treatment facility. Use 
of the SLD by WWD is subject to further NEPA review by USER. Any 
portion of the drain within this reach not used by WWD will be 
maintained with ponded water as discussed above. 

The southernmost reach of the drain is from Manning Avenue 
south to the end of the drain. This reach is upstream of the 
inflow points from WWD and is not thought to contain contami- 
nated sediments from the WWD subsurface system. This reach has 
historically been unused and is wet only during the winter 
months as a result of local drainage. No water will be sup- 
plied, and no changes in the management of this reach are pro- 
posed. 

Monitoring of groundwater, surface water, biota, and public 
health in the SLD vicinity will be implemented as part of SLD 
management. Monitoring results may indicate a need to excavate 
contaminated SLD sediments. Disposal of SLD sediments could 
occur at Kesterson Reservoir as part of the Onsite Disposal 
Plan; impacts of disposal of SLD sediments at Kesterson Reser- 
voir were described in the Draft EIS evaluation of the Onsite 
Disposal Plan. If a decision is made to dispose of SLD sedi- 
ments at an approved site other than Kesterson Reservoir, addi- 
tional environmental review would be necessary. 

USFWS environmentally preferred alternative for the SLD is 
the offsite disposal, in an environmentally acceptable manner, 
of the SLD sediments north of Manning Avenue. Once the contam- 
ination levels in the SLD south of Manning Avenue have been 
characterized, the USFWS will proposed an environmentally pre- 
ferred alternative for that reach. 



Biota Monitoring Program 

The initial monitoring plan for the SLD (not part of the 
UCB/LBL sampling program) will be restricted to collecting 
Gambusia and carp from the following SLD segments defined by 
Wallenstrom (1986) : 

o south of Manning Avenue to the southern end of the SLD. 

o between Manning and Bass Avenues. 

o between Bass Avenue and the SLD/DMC intertie (check 
no. 38) . 



2-44 



o between the SLD/DMC intertie and check no. 1. 

o from check no. 1 to the northern end of the SLD . 

Five Gambusia samples (at least 5 g wet weight per sample) 
will be collected from each of the above SLD segments for a 
total of 25 samples. Whole body analyses will be conducted for 
selenium. Carp may also be sampled (at the same frequency given 
for Gambusia ) , but the skeletal muscle and viscera of this 
species will be analyzed separately. 

Groundwater Monitoring Program 

Objective . Groundwater will be monitored along the length 
of the SLD to investigate possible seepage points. 

Monitoring Site Locations . Monitoring site locations 
consist of a series of shallow observation wells distributed 
along the length of the SLD and check sites within the drain. 

Parameters and Frequency . Selenium, TDS , boron, chloride,, 
and sulfate will be measured on an annual basis. 

Field Measurements . Field measurements for pH, electrical 
conductivity, and water temperature will be made at each moni- 
toring location. 

Air Quality Monitoring Program 

No air quality monitoring is proposed as part of the SLD 
Management Plan. 



Surface Water Monitoring Program 

Objective . Surface water will be monitored along the 
length of the SLD to investigate possible contamination by 
sediments and to assure that unauthorized discharges into the 
SLD are not occurring. 

Monitoring Site Locations . Monitoring site locations will 
be the same locations as used for biota monitoring. 

Parameters and Frequency . Selenium, TDS, boron, chloride, 
and sulfate will be measured on a quarterly basis. 

Field Measurements . Field measurements for pH, electrical 
conductivity, and water temperature will be made at each 
monitoring location. 



2-45 



Public Health Monitoring Program 

The SLD public health monitoring program is described under 
the FRP public health monitoring program. 

Research 



Overview 

The research described below will add to knowledge regard- 
ing the effectiveness of alternative remedial actions in pro- 
tecting water quality and biota. It also will lead to refine- 
ments of the monitoring programs and the proposed action. 

Ongoing Research 

USER funded a research program proposed by scientists from 
UCB/LBL in August 1985. The early stages of the program empha- 
sized field hydrological and geochemical measurements, including 
collection of samples of the Reservoir-bottom sediments, sedi- 
ments of the upper aquifer, and groundwater. Ecological inves- 
tigations were also emphasized. 

USER and UCB/LBL have expanded and extended the research 
program to include more extensive field and laboratory investi- 
gations. The field investigations include hydrological, geo- 
chemical, biological, and ecological studies complemented by 
laboratory studies that include hydrologic computer modeling, 
soil property determinations, selenium speciation determina- 
tions, and ecological investigations. 

The hydrological investigations include the following: 
field measurement and characterization of the hydrologic proper- 
ties of the upper aquifer, laboratory measurement of the hydro- 
logic properties of the fine-grained surface layer, and develop- 
ment of a preliminary two-dimensional model of the extent of the 
contaminant plume (boron migration) . Specific hydrologic activ- 
ities include test well drilling, geophysical logging to define 
subsurface lithology, specific capacity pump tests to evaluate 
permeability distributions, chemical sampling and analysis to 
evaluate the lateral and vertical extent of the contaminant 
plume, and tracer and interference tests to measure average 
vertical and horizontal permeabilities. 

The geochemical investigations include characterizing both 
surface and groundwater within and around Kesterson Reservoir to 
determine the current extent of subsurface oxygenating condi- 
tions and their effects on selenium concentration in order to 
develop an effective remedial action strategy. The groundwater 
and contaminant movement studies will evaluate selenium concen- 
trations and the hydrogeological conditions of the upper aqui- 
fer. This research will be conducted in Pond 2 and consists of 



2-46 



construction of a 400-foot-long berm eastward from the inter- 
section of Ponds 2, 3, and 4 and drilling of a series of obser- 
vation wells in the berm. 

A geochemical and biological investigation of the effec- 
tiveness of the Flexible Response Plan is being conducted in the 
southern area (Pond 5) . The objective is to evaluate the re- 
sponse of selenium over time with the introduction of selenium- 
free low-TDS water. Surface water, soils, groundwater, vegeta- 
tion, and biota will be monitored. A small triangular-shaped 
plot in a portion of Pond 5 has been constructed, and selenium- 
free low-TDS water has been introduced into the enclosure. 

Other biological investigations, both field and laboratory, 
include determining the distribution of total selenium in Kes- 
terson Reservoir sediments and vegetation, determining the 
extent of selenium speciation, and quantifying selenium volatil- 
ization in the field. 

Some of the laboratory experiments, which are being con- 
ducted to augment the field data, include using field cores to 
simulate field techniques; columns are evaluated for water 
balance, soil properties, and selenium concentrations. The 
focus is to monitor each column with tensiometers , water samp- 
lers, Eh and pH electrodes, and possibly gas samplers. The 
objective is to determine the effects of different water appli- 
cation options. Laboratory simulations of selenium transport 
into the groundwater from various vadose zone treatments will be 
included. The laboratory experiments will allow for a greater 
degree of control of the field experiments in determining local 
transport and transformation processes. 

The ecological investigations include characterization and 
monitoring of the numbers, seasonal changes, and selenium con- 
tent of the Kesterson Reservoir biota. The three habitats being 
studied are permanently wet (Ponds 1-5) , seasonally wet (Ponds 
6-10) , and dry (Ponds 11 and 12) . The specific studies include 
dynamics of selenium uptake by important food chain species 
(including biomagnification) , the dynamics of selenium pathways, 
the conceptualization of selenium cycling in Kesterson 
Reservoir, and the change of selenium in Kesterson biota 
following the addition of low-selenium water over selenium-rich 
bottom sediments. 



Additional Research 

Additional research activities for Kesterson Reservoir have 
been proposed both by USER personnel and UCB/LBL staff scien- 
tists. The following research activities are under consider- 
ation. 

Discing/Harvesting Research . The objective is to evaluate 
the response of selenium to discing/harvesting. The focus is to 
monitor the surface water, soils, groundwater, vegetation, and 



2-47 



biota for selenium concentration in the late fall and winter 
after discing/harvesting. The experiments will be conducted in 
a dry area and in a seasonally wet area of Pond 11. 

Excavation Research . The objective is to determine the 
impacts and efficiency of excavating sediments. The focus is to 
monitor both excavated and unexcavated areas of a test plot 
hydrologically , geochemically , and biologically. Designed as 
small scale, the less-than-1-acre site will be placed in an area 
where the selenium concentration is greater than 4 mg/kg. 

Immobilization Research . The objective is to verify 
whether harvesting and removing vegetation will prevent wildlife 
contamination under the Immobilization Plan. The focus is to 
monitor the surface water, soils, groundwater, vegetation, and 
biota. During the implementation of the FRP, Pond 4 may be used 
for this research. 

Resaturation Research . The objective is to observe the 
effects of covering a dry area with selenium- free moderate-TDS 
water. The focus is to monitor groundwater, soils, surface 
water, vegetation, and biota. A dry/wet cycle of events may be 
studied in the southern area (Pond 1) , and the entire pond will 
be used for this test. Selenium-free moderate-TDS water will be 
applied to this pond, which has been at least partially dry 
since mid-June 1986. 



Summary of Annual Costs 

Tables 2-9 through 2-11 present annual cost estimates (in 
1986 dollars) for the FRP, Immobilization Plan, and Onsite 
Disposal Plan, respectively. Costs are broken down into capital 
costs and annual monitoring and operation costs. 

Costs presented in Tables 2-9 through 2-11 do not include 
costs of long-term mitigation. Estimated capital costs of 
implementing long-term mitigation as recommended by USFWS (pur- 
chase and development of 1,280 acres of offsite wetland, with a 
surface water supply and back-up well water supply) are up to 
$10 million. 

The cost estimates represent costs of the basic elements of 
each plan, and do not include costs of certain contingency 
actions that may be implemented based on monitoring results. 
For example, costs of the plans would increase if the following 
contingency actions are taken: 

o Management actions for seasonal wetlands in the northern 
ponds if contamination persists (FRP, Immobilization 
Plan) 

o Harvesting of vegetation in the southern ponds if food 
chain contamination persists (FRP) 

Fencing of the Reservoir for San Joaquin kit fox protec- 
tion as discussed in USBR's Biological Assessment (FRP, 
Immobilization Plan) 
Contaminated groundwater extraction (all plans) 



o 



2-48 



Table 2-9. Annual Flexible Response Plan Costs 
(Thousands of Dollars) 



Item 



Annual Cost 
Year 1 



Annual Cost 
Years 2-5 



Capital costs - KR 
Well construction 

Capital costs - SLD 
No capital costs 

Monitoring and operation 

Punping 

Hazing 

Normal operation 

Discing 

Monitoring 

TOTAL 



300 



70 
300 
150 

30 

1,450 

2,300 



70 
150 
150 

10 
770 



1,150 



Note: Long-term mitigation as recomended by USEVJS would add up to $10 million 
to capital costs. 



2-49 



Table 2-10. Annual Iimiobilization Plan Costs 
(Thousands of Dollars) 





Annual Cbst 


Item 


Year 1 


Capital costs - KR 




Wet harvest 


4,200 


Capital costs - SID 




No capital costs 


— 


Monitoring and operation 




Punping 


70 


Hazing 


300 


Normal operation 


150 


Discing 


30 


Monitoring 


1,450 



Annual Cost 
Years 2-5 



70 
150 
150 

10 
770 



TOTAL 



6,200 



1,150 



Note: Long-term mitigation as reconnended by USFWS would add up to $10 million 
to capital costs. 

May be required after first year. 



2-50 



Table 2-11. Annual Onsite Disposal Plan Costs 
(Thousands of Dollars) 



Annual Cost Annual Cost 

Item Year 1 Years 2-5 

Capital costs - KR 

Excavate material 7,300 

Construct landfill 8,100 

Sairpling 750 — 

Capital costs - SLD 

No capital costs — 

Monitoring and operation 

Puirping — — 

Hazing 300 a 

Normal operation 150 100 

Leachate treatment/disposal 220 150 

Discing 80 a 

Monitoring 1,000 450 

TOTAL 17,900 700 



Note: Long-term mitigation as recatimended by USFWS would add up to $10 million 
to capital costs. 

May be required after first year. 

Adding onsite disposal of SLD sediments to the proposed action would add 
approximately $5 million to capital costs. Excavating 1 million cubic yards 
of sediments and vegetation at Kesterson Reservoir and disposing onsite 
would add approximately $24 million to capital costs. Disposal of SLD 
sediments at an appropriate site other than Kesterson Reservoir would add 
approximately $12 million in capital costs. 



2-51 



2-52 



Chapter 3 



ENVIRONMENTAL IMPACTS, MITIGATION MEASURES, 
AND ENVIRONMENTAL COMMITMENTS 



Introduction 

The Draft EIS (Volume II of the Final EIS) evaluated the 
impacts of alternatives for Kesterson Reservoir and SLD cleanup, 
and mitigation actions under consideration. In response to 
comments on the Draft EIS, a more detailed description of the 
proposed action has been prepared, and refinements have been 
made to each plan included in the proposed action (Flexible 
Response, Immobilization, and Onsite Disposal) (see Chapter 2 
of this Final EIS) . 

The first section of this chapter summarizes the impacts of 
each plan, as refined; highlights refinements made to each plan 
following receipt of comments on the Draft EIS; and discusses 
major environmental issues associated with each plan. The 
second section of this chapter presents mitigation measures to 
reduce environmental impacts of each plan. The final section of 
this chapter describes environmental commitments (mitigation 
measures recommended for implementation) that will be undertaken 
if the proposed action is implemented. 

Summary of Environmental Impacts 

Table 3-1 presents a summary of the impacts of the FRP , the 
Immobilization Plan, and the Onsite Disposal Plan, as refined. 
The summary descriptions of impacts are based on the full 
discussion of impacts as presented in the Draft EIS, as well as 
the discussion of the impacts of each plan presented below. The 
discussion below emphasizes refinements that have been made to 
each plan and its impacts in response to Draft EIS comments; 
selected major environmental issues associated with the FRP and 
the Immobilization Plan are also discussed. 



Flexible Response Plan 

Summary of Impacts . The wet option of the FRP will be 
implemented in the southern ponds (1-5 and 7) , whereas the dry 
option will be implemented in the northern ponds (6 and 8-12). 
The impacts of each of these options were evaluated in the Draft 
EIS. Drying of the northern ponds will convert about 380 acres 
of northern pond wetland habitat to upland habitat; the remain- 
ing 230 acres will be seasonal wetlands. 



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3-12 



For the southern ponds, local groundwater will be used as a 
water supply, rather than CVP water conveyed via the SLD as 
proposed in the Draft EIS. This option was included as a miti- 
gation measure in the Draft EIS (pp. 4E-17 to 4E-18) ; any risks 
of contamination of CVP water through an unexcavated SLD, and 
impacts of constructing a SLD/DMC connection, are avoided by the 
use of local groundwater as a water supply. 

Herbicide spraying, vegetation harvesting, and vegetation 
disposal through incineration or landfilling have been deleted 
from the FRF, thereby avoiding the impacts of these vegetation 
control measures. Instead, vegetation in the northern ponds 
will be controlled through discing. Cattail stands supporting 
tricolored blackbird colonies will be controlled in the southern 
ponds through harvesting only if monitoring shows selenium 
concentrations in the food chain are not being reduced. 

Finally, the wetland mitigation alternative of providing a 
new water supply to existing wetlands has been added as an 
alternative to the purchase and development of offsite wetlands. 
See Draft EIS discussion of this option, p. 3-12, and see des- 
cription under FRP nuisance abatement program in Chapter 2 of 
this Final EIS. The use of 8,000-12,000 acre-feet of CVP water 
would constitute an interim water supply. No effect on other 
water users with long-term CVP contracts would occur. No direct 
impacts on Delta pumping or Delta water quality are expected. 
The impacts of the potential long-term use of CVP water for 
mitigation will be addressed in USBR's Refuge Water Supply EIS 
which is expected to be issued in late 1987. 

Potentially significant impacts associated with the FRP are 
listed below. All impacts are capable of mitigation except 
those identified with a double asterisk (**) , which are unavoid- 
able. 



Kesterson Reservoir ; 

o Continuation of hazing noise ** 

o Selenium leaching, and risks of groundwater contamina- 
tion, in the northern ponds similar to no action 

o Rising groundwater with initially high selenium concen- 
trations covering 230 acres of the northern ponds 
seasonally 

o Reduced, but continued, risks of contamination of vege- 
tation and wildlife ** 

o Reduced, but continued, risks of contamination of 
reestablished fisheries 

o Reduced, but continued, wildlife use of the Reservoir 

o Loss of 380 acres of wetland vegetation and wildlife 
habitat in the northern ponds due to drying (of the 
approximately 1,240 net acres of Reservoir wetlands, 380 
acres in the northern ponds will convert to upland 
habitat, 230 acres in the northern ponds will be 



3-13 



seasonal wetlands, and 630 acres in the southern ponds 

will be permanently wet) 

Continued loss of prior artificially created Reservoir 

fisheries habitat in the northern ponds 

Potential continued loss of use of Reservoir wetlands 

for recreational and wildlife uses, and potentially 

reduced short-term recreational opportunities at duck 

clubs due to hazing 

Short-term potential for continued perception of reduced 

quality of life experienced by residents of Gustine and 

those adjacent to the Reservoir 

Changes in the visual character of the Reservoir from 

discing ** 



SLD ; 

o Reduced, but continued, risks of contamination of SLD 
vegetation, fisheries, and wildlife from SLD sediments 

Offsite Mitigation Parcels ; 

o Potential conversion of prime farmland to wetlands on 

offsite mitigation parcels 
o Possible effects on unidentified cultural resources at 

the offsite mitigation parcels 

Major Issues . Reviewers of the Draft EIS, and USBR's 
proposed action, have focused on a nun±)er of specific environ- 
mental issues associated with the FRP and its impacts. USBR 
recognized in the Draft EIS that the FRP wet option poses poten- 
tially significant risks to wildlife, and recognizes that risks 
such as those identified by Draft EIS reviewers may be present. 

Under its phased approach, USBR proposes to implement the 
FRP in March 1987 only if the latest available data indicate 
that the FRP may achieve cleanup goals by 1992. USBR proposes 
to continue the FRP only if annual monitoring reports continue 
to show that cleanup goals (defined in the Summary and Chapter 2 
of this Final EIS) may be achieved by 1992. The biological 
monitoring program to be implemented as part of the FRP express- 
ly recognizes the potential importance of biological processes 
in selenium cycling and mobilization, and is designed to measure 
the magnitude of risks for biota such as those mentioned by 
Draft EIS reviewers. 

Indications to date, based on reported results of UCB/LBL 
research, that the FRP may be successful in achieving cleanup 
goals for groundwater, surface water, and biota include the 
following: 



3-14 



o Groundwater monitoring data show that, except in two 
locations, selenium is generally being contained in the 
Reservoir sediments and not leaching to groundwater. 

o Surface water monitoring in Pond 5 and the experimental 
pond enclosure 5e show that surface water selenium 
concentrations are rapidly declining with the addition 
of clean water to these ponds, suggesting that selenium 
mobilization from the sediments to clean surface water 
may not be a major concern. 

o Limited sampling to date indicates the apparent lack of 
true benthos species in the southern ponds, suggesting 
that food chain contamination via benthos in the 
southern ponds may not be a major concern. 

Specific concerns related to the FRP raised by reviewers of 
the Draft EIS, in particular USFWS , are summarized below. 

Importance of Risks to Fish and Wildlife in the 
Southern Ponds 

Adequacy of Geochemical Models in a Biogeochemi- 
cal Environment . USFWS believes that much of the reasoning that 
USER and its researchers have used in justifying the FRP and 
Immobilization Plan has been based on geochemical modeling of 
the Kesterson Reservoir environment (LBL 1985a; LBL 1985) . 
USFWS believes that the use of geochemical models does not 
adequately address the entire environiriental system at Kesterson 
Reservoir, and that biological processes must be incorporated 
into the evaluation of contamination and cleanup techniques. A 
biogeochemical analysis of the Kesterson Reservoir environment 
would include, in addition to geochemical processes, the invest- 
igation of microbial, catalytic, macroinvertebrate , bacterial, 
and vegetative processes which account for important selenium 
cycling and mobilization mechanisms in the various Reservoir 
habitats • 

Importance of Detrital Food Pathways for Seleni- 
um Cycling and Biological Mobilization . USFWS believes that 
USBR and its researchers have underestimated the variety, num- 
ber, and over-all importance of benthic-feeding organisms. 
These organisms, which use and are a part of the detrital food 
pathways, contribute to selenium cycling and biological mobili- 
zation. Processes such as bioturbation, the physical transloca- 
tion of sediments by burrowing and feeding benthic organisms 
(e.g., chironomids) (Davis 1974; Brinson et al. 1981), and 
microbial mobilization, such as bacterial oxidation and methyla- 
tion, (Sarathchandra et al. 1981; Cutter 1982, 1984; Doran 1982; 
Chau et al, 1976; Nalepa et al. 1980; Webb 1981; Bass 1986) are 
examples of activities which remobilize selenium from the sedi- 
ments and into the food chain. Moreover, aquatic bacteria 
accumulate selenium to very high concentrations (Guthrie and 
Cherry 1979) and can serve as an effective link between abiotic 



3-15 



and biotic (food chain) components of aquatic systems (Wetzel 
1975) . Other benthic feeding organisms include cranefly larvae 
and soldierfly larvae, which have been noted by USER researchers 
to occur in Kesterson Reservoir (LBL 1986) . 

USFWS believes that direct use of the sediments by benthic 
detritivores (e.g., ostracods) which feed on the protozoan and 
bacterial fauna of benthic sediments (Berrie 1976; Doran 1982; 
Diner et al. 1986) , and then are in turn consumed by sedi- 
ment-sieving shore and water birds (Mason 1986; Cogswell 1977; 
Ohlendorf et al. in press a), has also been underestimated by 
the USER. USFWS believes that USER also has overlooked the fact 
that completely anoxic conditions would not lilcely be main- 
tained permanently or uniformly in the Reservoir (Wetzel 1975; 
Godshalk and Wetzel 1978; Ayyappan et al. 1986). With the 
ability for hypoxic conditions to exist in the Reservoir sedi- 
ments, USFWS believes that the survival of a variety of benthic 
and lentic organisms will undoubtably occur (Tinson and 
Laybourn-Parry 1985; Merritt and Cummins 1984) . 

Importance of Microbial Speciation and Mobi- 
lization of Selenium from the Surficial Sediments and Into the 
Water Column . USFWS believes that microbial speciation and 
mobilization of selenium from the sediments will occur through 
oxidation, which results in selenite (Sarathchandra et al. 1981; 
Cutter 1982; Cutter 1984) , and methylation, which results in 
dimethylselenide and other methylated forms (Doran 1982; Chau et 
al. 1976). Selenite and dimethylselenide have been determined 
to be present in the Kesterson Reservoir surface waters from LBL 
analyses (LBL 1986) . USFWS believes that this observation 
substantiates the fact that the flux of selenium is not unidi- 
rectional, as suggested by the FRP and Immobilization Plan and 
the theories which support these alternatives. A strain of 
bacteria has been isolated that oxidizes elemental selenium to 
selenite (Sarathchandra et al. 1981) . Also, it has been shown 
that microbes can oxidize metal selenides to elemental selenium 
(Torna and Habishi 1972) , demonstrating another potential path- 
way for selenium mobilization. In addition, anoxic conditions 
near sediment/water interfaces of the Reservoir may tend to 
stabilize thermodynamically unstable organic species of selenium 
(selenomethionine, selenocystine , etc.), thus increasing their 
bioavailability (Cutter 1984) . USFWS believes that the proces- 
ses of decomposition will cause methylation and the generation 
of volatile alkylated forms of selenium such as dimethylselenide 
(Doran 1982) ; aquatic plants are known to adsorb this form of 
selenium (Wehr and Brown 1985) , which provides the mechanism for 
the recycling of selenium into the food chain. 

Importance of Organic Selenium (Dimethylselenide) 
and Selenite in Surface Water . USFWS believes that an important 
factor regarding the release of dimethylselenide from the sedi- 
ments into the surface waters is the ability of algae, such as 
the Nitella species which occurs in Kesterson Reservoir, to take 
up this form of organic selenium and recycle it back into the 



3-16 



food chain (Wehr and Brown 1985) . USFWS notes that selenite 
present in surface waters is very bioavailable and much more 
toxic than selenate, the form of selenium which entered the 
Reservoir from agricultural drainwater (Sandholm et al. 1973; 
Adams 1976; Butler and Peterson 1967; Sharma and Davis 1980; 
Niimi and LaHam 1976; Kleinow and Brooks 1986; Kumar and Prakash 
1971; Boyum 1984; Bennett 1984). 

Bioavailability and Toxicity of Organic Selenium 
and Selenite . Information available to date leads USFWS to the 
conclusion that organic forms of selenium, such as selenomethio- 
nine, are the most toxic, followed by selenite and selenate 
(Sandholm et al. 1973; Adams 1976; Sharma and Davis 1980; 
Kleinow and Brooks 1986; Bennett 1984) . If present, all of 
these forms of selenium are bioavailable (Sandholm et al. 1973; 
Butler and Peterson 1967; Sharma and Davis 1980; Kleinow and 
Brooks 1986; Bennett 1984) . 

Importance of Selenium Mobilization as Caused by 
Physical Resuspension and Bioturbation . USFWS believes that 
physical resuspension of pond sediments is likely to occur due 
to wind/wave action, rainfall, and seasonal and diurnal turn- 
over, contributing to aerobic sediments. This, in turn, will 
lead to the potential for increased recycling of selenium from 
the sediments and into the food chain (Cumbie 1978, 1984). 
Bioturbation is the physical translocation of sediments, and is 
accomplished through burrowing and feeding activity of benthic 
organisms. USFWS believes that invertebrates identified as 
being present in Kesterson Reservoir (LBL 1986) are involved in 
the uptake and excretion of ■ phosphorus (Holdren et al. 1980; 
Shaver and Melillo 1984) , the active transport of particulate 
material from the sediments to the sediment-water interface and 
into deeper sediment layers (Davis 1974) , and the egestion of 
fecal material at the water-sediment interface (Brinson et al . 
1981). Together with microbial interactions, those processes 
provide an important pathway for the cycling and mobilization of 
selenium, some of which would occur even if the Reservoir sedi- 
ments could be kept uniformly anaerobic across all habitats and 
seasons (Nalepa et al. 1980; Webb 1981; Bass 1986; Doran 1982; 
Cutter 1982; Chau et al. 1976). 

Effectiveness of Chemical Reduction, Adsorption, 
Complexation, and Precipitation in Affecting Selenium Immobili- 
zation in Surficial Sediments and Detritus . While recognizing 
that these processes do occur, and facilitate the movement of 
selenium from the water column to the sediments, USFWS notes 
that it must also be recognized, as noted in the above comments, 
that the flux of selenium in the Reservoir environment is not a 
unidirectional process. USFWS believes recent findings by USBR 
researchers regarding detrital feeding invertebrates and selen- 
ium speciation in surface waters (LBL 1986) confirm that selen- 
ium does cycle from the sediments and into the food chain within 
Kesterson Reservoir. These findings diminish the overall impor- 
tance of immobilization processes in the context of reducing or 



3-17 



eliminating the toxic effects of selenium on the fish and wild- 
life resources of Kesterson Reservoir. 

Uncertainty Regarding the Ability to Predict When 
Selenium Residues will Decline to Safe Levels . USFWS believes 
that many factors suggest that a nonlinear relationship exists 
between the decline of selenium residues in the water and biota, 
and the time it takes to reach safe levels. Many environmental 
processes are biphasic or second order or higher in nature, and 
therefore, prediction of rates of residue decline are often 
impossible without full elucidation of mediating processes and 
kinetic order. Without a large data base, it is often impos- 
sible to predict when residues will decline to safe levels and 
at what concentration a pseudo-steady-state condition will be 
achieved. Even if biologically available selenium residues 
initially decrease dramatically, USFWS believes that there is 
considerable evidence that bioconcentration factors go up as 
water concentrations go down (Adams 1976; Hodson and Hilton 
1983) , thereby further reducing the accuracy of prediction. 
USFWS therefore concludes that the site will still be expected 
to exhibit toxic hazards to fish and wildlife and cause undesir- 
able and detrimental effects to local and regional populations. 

Bioaccumulation and depuration of selenium by aquatic 
organisms is a complex process, with rates mediated by such 
things as exposure concentrations (Hodson and Hilton 1983), 
chemical forms (Sandholm et al. 1973; Sharma and Davis 1980), 
ratios of dietary to waterborne selenium (Lemly 1982; Lemly 
1985; Boyum 1984; Bertram and Brooks [in press]; Bennett 1984), 
and water quality (Lemly 1982; Fowler and Benayoun 1976) . USFWS 
believes that there is, however, at least one unifying theme: in 
the initial phases, both accumulation and depuration occur in a 
curvilinear pattern. If there is a continued flux from a con- 
taminated source (e.g., water, food, sediments), residual selen- 
ium will persist at elevated levels (Cherry et al . 1979; Cherry 
et al. 1984; Sorenson et al. 1983; Sorenson et al. 1982; 
Garrett and Inman 1984; Texas Utilities Generating Company 
1986) . Because of the complex relationships and variables that 
will affect depuration kinetics in the environment such as 
seasonal/spatial changes in water quality and selenium fluxes, 
USFWS believes that short-term depuration tests, and linear 
extrapolation from these limited observations, cannot be judged 
as accurate methods of predicting what the biological concen- 
trations or potential long-term toxicity may be at any point in 
time . 

Importance of Risks to Wildlife in the Northern Ponds . 
USFWS believes that risks to wildlife utilizing the northern 
ponds are significant, and that when these ponds flood up in the 
fall/winter, risks will be the same, or perhaps greater, as 
risks discussed for the southern ponds above. Selenium will be 
bioavailable in the ponded surface water, plants, and inverte- 
brates. Traditionally this area has provided important habitat 
for nesting and feeding by waterfowl, shorebirds, and passer- 
ines. USFWS believes that potentially significant risks to 

3-18 



small mammals would also exist, as vegetative and invertebrate 
food sources tor mice, voles, shrews, and other small mammals 
remain contaminated. USFWS believes that further up the food 
chain, larger avian and mammalian predators, including the 
endangered San Joaquin kit fox, would be exposed to the con- 
taminated prey base. 

It should be noted that the above risks of the FRP dry 
option were recognized in the Draft EIS. Following completion 
of research to verify its effectiveness, the dry areas of the 
northern ponds will be disced to reduce the availability of 
wildlife food and cover. Seasonal wetlands in the northern 
ponds will be monitored, and if monitoring indicates cleanup 
goals may not be achieved, discing, harvesting, or filling may 
be implemented. 

Adequacy of Existing Research Data to Support FRP . 
USFWS believes that there is ample evidence from the scientific 
literature (portions of which are referenced in this chapter of 
the Final EIS) that implementation of the proposed FRP and 
Immobilization Plan will not remove selenium contamination risks 
to fish and wildlife resources, and that to date, no actual 
field experiments or research have generated statistically valid 
scientific data under a written and certified QA/QC program that 
provide substantive evidence to the contrary. 

There are several indications to date, based on reported 
results of UCB/LBL research, that the FRP may be successful in 
achieving cleanup goals for groundwater, surface water, and 
biota, as discussed previously. QA/QC concerns raised by USFWS 
are being addressed through a reanalysis of selected previous 
samples, and by ongoing modification of the UCB/LBL QA/QC pro- 
gram. 

Importance of Risks to Wildlife from Leaving SLD 
Sediments in Place . Many of the same risks and concerns for the 
health of the fish and wildlife populations at Kesterson Reser- 
voir identified by USFWS apply to the SLD. Selenium may cycle 
from the sediments into the surface water of the drain as well 
as into biota living in the drain sediments. Detrimental ef- 
fects may occur to fish and wildlife feeding on drain vegetation 
and invertebrates. 

USBR recognized these risks in the Draft EIS, and is pro- 
posing to cover contaminated SLD sediments north of Manning 
Avenue with clean water, rather than excavate contaminated SLD 
sediments, based on the following assumptions: 1) selenium can 
be contained in the SLD sediments; 2) application of clean water 
eliminates a primary selenium exposure pathway (surface water); 
and 3) there is a relative lack of vegetation, fish, and wild- 
life resources using the SLD. Groundwater, surface water, 
biota, and public health in the SLD vicinity will be monitored 



3-19 



as part of SLD management to verify that selenium is being 
immobilized in the SLD sediments. 

Cleanup Goal for Selenium Concentrations in Surface 
Water . USFWS concludes that it is clear from studies of aquatic 
systems elsewhere that both water and diet contribute to biolog- 
ical uptake of selenium. Studies that have examined both 
sources in one organism show that dietary selenium is responsi- 
ble for a majority of the residue if waterborne concentrations 
are sublethal (Sandholm, et al. 1973; Lemly 1982, 1985; Boyum 
1984; Bertram and Brooks [in press]; Bennett 1984). This pheno- 
menon is caused by bioaccumulation of selenium as it moves 
through the food chain. 

USFWS believes that the ecological data base now available 
clearly shows that 8-12 yg/1 selenium, as total recoverable 
selenium in filtered (less than or equal to 10 microns) water 
samples, can result in chronic toxicity (i.e., reproductive 
failure and dietary toxicity via food chain bioaccumulation and 
biomagnif ication) to warm-water fishes. Numerous studies of a 
power-plant cooling reservoir in North Carolina (Belews Lake) 
show that, in the absence of other toxicants, selenium at water- 
borne levels of 8-12 yg/l (total recoverable, filtered) can 
cause total reproductive failure and mortality of fishes 
(centrarchids, percids, perichthyids , ictalurids, catostomids, 
cyprinids, and clupeids) (Duke Power Company 1980; Sorenson et 
al. 1984; Lemly 1985; Cumbie and Van Horn 1978) . The adverse 
effects upon fishes at Belews Lake caused by long-term exposure 
to 8-12 yg/1 selenium were corroborated in studies of two other 
reservoirs in North Carolina with elevated levels of total 
waterborne selenium (Woock and Summers 1984; Woock and Cofield 
1983) . Reproductive failure associated with these waterborne 
concentrations has also been demonstrated experimentally in the 
laboratory (Gillespie and Baumann 1986) . The above-referenced 
studies also revealed that 2-5 yg/1 selenium may be safe to 
aquatic life in those freshwater systems. 

Based upon: a) the findings of these studies; b) the fact 
that migratory birds feed upon many of the same organisms as 
fishes yet some waterfowl species may be adversely affected by 
lower concentrations of selenium in the diet than some fishes 
(Wallenstrom pers. comm.); and c) the fact that Kesterson Reser- 
voir lies within a National Wildlife Refuge established and 
managed for the protection and perpetuation of fish and wild- 
life, USFWS believes it prudent to adopt a conservative (i.e., 
low) level of total waterborne selenium to ensure the protection 
of freshwater aquatic life and other wildlife that feed upon 
aquatic biota from Kesterson Reservoir. Therefore, USFWS be- 
lieves that until new, substantiated research findings support a 
different value, a preliminary MATC of 2 yg/1 in surface waters 
(as total recoverable selenium) should be used as one measure to 
assess successful cleanup of Kesterson Reservoir. Ongoing 
selenium toxicity research being conducted by USFWS may result 



3-20 



in a modification (either an increase or decrease) of this 
recommendation . 

USER proposes a surface water selenium goal of 5 pg/1, 
rather than 2 ug/1. This value is within the 2-5 pg/1 range 
currently considered safe by USFWS to aquatic life in reser- 
voirs. It is also within the range of 2-10 yg/l currently being 
considered by the SWRCB on potential water quality objectives 
for the San Joaquin River basin. Ongoing selenium toxicity 
research may result in a modification (either an increase or 
decrease) of this initial cleanup goal. 



Immobilization Plan 

Summary of Impacts . The pond option of the Immobilization 
Plan will be implemented in the southern ponds if monitoring 
indicates that the FRP may not be successful in achieving selen- 
ium reduction goals, but that immobilization as monitored in 
Pond 4 may be successful in achieving the goals. Impacts of the 
pond option were evaluated in the Draft EIS (Volume II of the 
Final EIS). In the northern ponds, the dry option of the FRP 
will be continued under the Immobilization Plan, resulting in 
about 380 acres of upland habitat and 230 acres of seasonal 
wetlands. 

Refinements made to the Immobilization Plan are similar to 
those described above for the FRP. Local groundwater, rather 
than CVP water, will be used as the water supply for the south- 
ern ponds. Vegetation control in the northern ponds will employ 
discing. The wetland mitigation alternative of providing a new 
water supply to existing wetlands has been added. 

Potentially significant impacts associated with the Immobi- 
lization Plan are listed below. All are capable of mitigation 
except those identified with a double asterisk (**) , which are 
unavoidable . 

Kesterson Reservoir ; 

o Continuation of hazing noise ** 

o Selenium leaching, and risks of groundwater contamina- 
tion, in the northern ponds similar to no action 

o Rising groundwater with initially high selenium concen- 
trations covering 230 acres of the northern ponds 
seasonally 

o Reduced, but continued, risks of contamination of vege- 
tation and wildlife ** 

o Reduced, but continued, risks of contamination of 
reestablished fisheries 

o Reduced, but continued, wildlife use of the Reservoir 

o Loss of 380 acres of wetland vegetation and wildlife 
habitat in the northern ponds due to drying (of the 
approximately 1,240 net acres of Reservoir wetlands, 380 



3-21 



acres in the northern ponds will convert to upland 
habitat, 230 acres in the northern ponds will be season- 
al wetlands, and 630 acres in the southern ponds will be 
permanently wet) 

Continued loss of prior artificially created Reservoir 
fisheries habitat in the northern ponds 

Potential continued loss of use of Reservoir wetlands 
for recreational and wildlife uses, and potentially 
reduced short-term recreational opportunities at duck 
clubs due to hazing 

Short-term potential for continued perception of reduced 
quality of life experienced by residents of Gustine and 
those adjacent to the Reservoir 

Changes in the visual character of the Reservoir from 
discing ** 



SLD ; 

o Reduced, but continued, risks of contamination of SLD 
vegetation, fisheries, and wildlife from SLD sediments 

Offsite Mitigation Parcels : 

o Potential conversion of prime farmland to wetlands on 

offsite mitigation parcels 
o Possible effects on unidentified cultural resources at 

the offsite mitigation parcels 

Major Issues . Reviewers of the Draft EIS, and USBR's 
proposed action, have focused on a number of specific environ- 
mental issues associated with the Immobilization Plan and its 
impacts. The concerns raised by these reviewers, and USBR's 
responses, are similar to those discussed previously for the 
FRP. 



Onsite Disposal Plan 

The Onsite Disposal Plan will be implemented if monitoring 
indicates that neither the FRP nor the Immobilization Plan will 
be successful in achieving cleanup goals. Impacts of the Onsite 
Disposal Plan were evaluated in the Draft EIS. 

A number of refinements were made to the Onsite Disposal 
Plan in response to comments on the Draft EIS. Most important- 
ly, because of concerns expressed regarding possible contami- 
nation of restored wetlands from residual contaminants following 
excavation, no active attempt will be made to restore Kesterson 
Reservoir through provision of a water supply. Without adding 
water to the Reservoir, about 780 acres of the Reservoir will 
become upland habitat, about 40 acres of Pond 3 will be used for 
the onsite landfill and buffer area, and about 420 acres will be 
seasonal wetlands. Because wetland restoration will not be 



3-22 



attempted onsite, additional offsite wetland mitigation will be 
considered. 

Under the Onsite Disposal Plan as refined, about 450,000 
cubic yards of the most contaminated soils and vegetation, 
rather than the 1.1 million cubic yards evaluated in the Draft 
EIS, will be excavated, thereby reducing the impacts of excava- 
tion and landfilling while still removing most of the selenium 
contamination (see Draft EIS discussion of this mitigation 
measure, p. 4A-72). The groundwater extraction program des- 
cribed in the Draft EIS will not be implemented unless ground- 
water monitoring data indicate a need for this contingency 
program, since excavation of contaminated soils and vegetation 
will greatly reduce risks of groundwater contamination. 

Other refinements to the Onsite Disposal Plan consist of 
deletion of construction of an SLD/DMC connection addition of 
the wetland mitigation alternative of providing a new water 
supply to existing wetlands, and deletion of SLD sediment exca- 
vation at this time, since the SLD would not be used to convey 
CVP water to Kesterson Reservoir. 

Potentially significant impacts associated with the Onsite 
Disposal Plan are listed below. All impacts are capable of 
mitigation except those identified with a double asterisk (**), 
which are unavoidable. 

Kesterson Reservoir ; 

o Potential ground-settling damage to onsite landfill 
liner 

o Particulate (dust) emissions from excavating site soils 
and landfill construction 

o Short-term heavy equipment noise from excavation and 
landfill construction 

o Reduced, but continued, wildlife use of the Reservoir 

o Continued loss of prior artificially created Reservoir 
fisheries habitat 

o Loss of a total of 820 acres of wetland vegetation and 
wildlife habitat in both northern and southern ponds due 
to drying and landfill construction (of the approximate- 
ly 1,240 net acres of Reservoir wetlands, 780 acres will 
be converted to uplands, 40 acres will be used for land- 
fill and buffer, and 420 acres will be seasonal wet- 
lands) 

o Continued loss of use of Reservoir wetlands for recrea- 
tional and wildlife uses 

o Significant construction noise during construction 
period 

o Short-term potential for continued perception of reduced 
quality of life experienced by residents of Gustine and 
those adjacent to the Reservoir 

o Changes in the visual character of the Reservoir from 
construction activities, onsite landfill, and drying of 
southern ponds ** 

3-23 



SLD ; 

o Reduced, but continued, risks of contamination of SLD 
vegetation, fisheries, and wildlife from SLD sediments 

Offsite Mitigation Parcels ; 

o Potential conversion of prime farmland to wetlands on 

offsite mitigation parcels 
o Possible effects on unidentified cultural resources at 

the offsite mitigation parcels 

Mitigation Measures 

Applicable mitigation measures to reduce adverse impacts of 
each of the three plans are listed in Table 3-2. This table 
lists mitigation measures identified in the Draft EIS, as well 
as additional mitigation measures suggested by Draft EIS com- 
menters. The table does not list monitoring programs (biota, 
groundwater, air quality, surface water, and public health) 
since they are already included in USBR's proposed action (see 
Chapter 2). Based on the results of these monitoring programs, 
either specific contingency actions (e.g., groundwater extrac- 
tion, filling seasonal wetlands) , or the next phase of the 
proposed action may be implemented. 

In general, impacts associated with risks of groundwater 
contamination will be mitigated to less-than-signif icant levels 
by implementation of a corrective-action program (i.e., ground- 
water extraction) if monitoring indicates contamination. Also, 
the purchase of appropriate surrounding private lands will be 
considered if it is later determined that the influence of 
Kesterson Reservoir on groundwater is adversely affecting such 
lands to an extent that justifies such action, or if other 
programmatic purposes justify this action. This action would 
also further mitigate any quality of life impacts caused by 
cleanup activities, such as hazing and construction noise, dust, 
and traffic. 

Impacts associated with continued risks of biota contami- 
nation will be partially mitigated by nuisance abatement activi- 
ties, and implementation of an alternative plan if monitoring 
indicates that selenium-reduction goals are not being achieved. 
Long-term wetland mitigation measures to recreate habitat values 
provided by Kesterson Reservoir prior to its contamination by 
subsurface agricultural drainage are being considered by DOI. 
Alternatives under consideration include provision of a new 
water supply to existing wetlands and/or purchase and devel- 
opment of offsite wetlands. USFWS recommends the establishment 
of 1,280 acres of new wetlands of comparable habitat values to 
those provided by Kesterson Reservoir prior to contamination. 



3-24 



Table 3-2. Kesterson Program Mitigation Measures 



Flexible Onsite Rationale 

Response Iimcbilization Disposal For Measures 
Plan Plan Plan Not Selected 



Ttopogr^hy, Geology, and Soils 
A. Kesterson Reservoir 

Keep ponds wet prior to flooding + 
Flood ponds daring winter after drying - 
Reduce volume of excavated soils NA 



B. 
C. 



Design landfill to meet Sub- 
ch^ter 15 requirements 

Mulch or plant windbreaks 

SLD 

Of fsite Mitigation Areas 

Avoid Gallo prcperty excavation 



NA 



NA 



NA 



NA 



NA 



NA 



- 


NA 


Ponds will not dry 


NA 


+ 




NA 


+ 




_ 


_ 


Not effective 



NA 



II. Air Quality 

A. Kesterson Reservoir 

Mulch or plant windbreaks - 

Daiipen work-area soils to reduce NA 
dust 

Reduce volume of excavated soils NA 

B. SLD NA 

C. Of fsite Mitigation Areas 

Avoid excavation at Gallo property NA 



NA 

NA 

NA 

NA 



Not effective 



+ 
NA 



III . Noise 



Kesterson Reservoir 

Use mufflers on harvesters 

Use nufflers on heavy equipnent 

Limit harvest activity to 8 hours 
per day 

Avoid excavation at Gallo property 

SLD 

Offsite Mitigation Areas 

Use mufflers on heavy equipment 



NA 


+ 


NA 


+ 


+ 


+ 


NA 


+ 


NA 


NA 


NA 


+ 


NA 


NA 


NA 



IV. Groundwater 

A. Kesterson Reservoir 

Keep ponds wet prior to flooding + 
Flood ponds during winter after drying - 
Reduce volume of extracted groundwater + 



NA 

NA Ponds will not dry 

+ 



3-25 



Table 3-2. (Ccaitinued) 



I 



Flexible Onsite Rationale 

Response Iitinobilization Disposal For Measures 
Plan Plan Plan Not Selected 



Refine extraction well network de- + + + 

sign to reduce drawdcwn 

B. SLD NA NA NA 

C. Otfsite Mitigation Areas NA NA NA 

V. Surface Water 

A. Kesterson Reservoir 

Keep ponds v^t prior to flooding + + HA 

Flood ponds during winter after drying - - NA Ponds will not dry 

B. SLD 

Use local groundwater source in + + NA 

lieu of CVP water 

C. Offsite Mitigation Areas NA NA NA 

VI. Vegetation 

A. Kesterson Reservoir 

Select another alternative if con- + + NA 

tamination continues 

Inplanent nuisance abatement program + + + 

(i.e., short-term mitigation) 

Provide long-term mitigation to a a a 

recreate Reservoir habitat values 
that existed prior to contamination 

B. SID 

Control SLD vegetation as necessary + + + 

Provide long-term mitigation to a a a 

recreate SLD habitat values that 
existed prior to contamination 

C. Offsite Mitigation Areas NA NA NA 

VII. Fisheries 

A. Kesterson Reservoir 

Establish fisheries in offsite + + + 
mitigation wetlands 

Do not restock fish in Reservoir + + NA 

unless selenium contamination 

eliminated 

^- SLD NA NA NA 

C. Offsite Mitigation Areas NA NA NA 



3-26 



Table 3-2. (Continued) 



Flexible Onsite Rationale 

Response Imnobilization Disposal For Measures 
Plan Plan Plan Not Selected 



VIII. Wildlife 



A. Kesterson Reservoir 

Select another alternative if con- 
tamination continues 

Iitplejnent nuisance abatenent program 
(i.e., short-term mitigation) 

Provide long-term mitigation to 
recreate Reservoir habitat values 
that existed prior to contamination 

Avoid excavation of Gallo property 
and soil inportation to Reservoir 

B. SLD 

Control SID vegetation as necessary 

Provide long-term mitigation to 
recreate SID habitat values that 
existed prior to contamination 

C. Off site Mitigation Areas 



NA 

+ 
a 

Id 



NA 



NA 

+ 
a 

NA 



+ 
a 

NA 



IX. 



Land Use 



X. 



B. 
C. 



Kesterson Reservoir 

Inplement nuisance abatement 
program (i.e., short-term 
mitigation) 

Provide long-term mitigation to 
recreate Reservoir habitat values 
that existed prior to contamination 

SID 

Of fsite Mitigation Areas 

Avoid prime farmland conversion 



Population, Housing, and Social Environment 

A. Kesterson Reservoir 

Purchase of appropriate surrounding 
private lands (if determined to 
be warranted) 

Implement noise mitigation mea- 
sures 

Keep public informed of Kesterson 
Program activities 

B. SID 

Keep public informed of Kesterson 
Program activities 

C. Of fsite Mitigation Areas 

Keep public informed of Kesterson 
Program activities 



NA 



NA 



NA 



No feasible alternative 
sites exist if offsite 
wetlands developed 



3-27 



Table 3-2. (Continued) 



Flexible Onsite Rationale 

Response Inmobilization Disposal For Measures 
Plan Plan Plan Not Selected 



i 

i 



XI. 



Public Health 



Kesterson Fteservoir 

continue hazing as necessary + 

Continue public awareness program + 

Implement air quality mitigation 
measures 

Use protective breathing devices NA 
and monitor personal air quality 
during excavation 

Reduce volume of excavated soils NA 

Relocate adjacent residents during NA 
excavation 

SID 

Continue public awareness program + 

Fence SLD 



Of fsite Mitigation Areas ICV 



+ 
+ 

NA 

NA 
NA 



+ 
+ 



See air quality mitiga- 
tion measures 



Air quality and public 
health mitigation mea- 
sures sufficient to pro- 
tect residents 



Public awareness program 
sufficient to protect 
public health 



NA 



NA 



XII. Recreation and Transportation 

A. Kesterson Reservoir 

Provide recreation at of fsite mit- 
igation wetlands 

B. SLD 

C. Of fsite Mitigation Areas 

Avoid importation of soil fron 
Gallo property 



NA 



NA 



NA 



NA 



NA 



XIII. Energy 

A. Kesterson Reservoir 

Reduce volume of excavated 
soils 

Avoid inportation of soil fron 
Gallo property 

B. SLD 

C. Offsite Mitigatiai Areas 



NA 

NA 

NA 

NA 



NA 

NA 

NA 
NA 



NA 
NA 



XIV. Cultural Resources 



Kesterson Reservoir 

Consult with SHPO and ijtplenent 
recciitnended mitigations 



NA 



NA 



3-28 



Table 3-2. (Continued) 



Flexible 




Onsite 


Rationale 


Response 


Iitmcbilization 


Disposal 


For Measures 


Plan 


Plan 


Plan 


Not Selected 



B. SID NA NA MR 

C. Offsite Mitigation Areas 



Consult with SHPO and iirplanent 
recxiimended mitigations 



Legend: + = recatmended for inplemsntation. 

- = not recatmended for inplenientation. 

NA = not applicable to the plan in question, 

a = measures under consideration by the Department of the Interior. 



3-29 



Environmental Coirnnitrnents 

The mitigation measures listed in Table 3-2 recommended for 
implementation (indicated with a "+") represent commitments by 
bSBR to reduce or avoid the adverse impacts of its proposed 
action. These measures, together with measures which are cur- 
rently under consideration or in the future may be considered 
(indicated with an "a") are described below according to the 
types of impacts they will mitigate (e.g., surface water or 
vegetation) . The initials after each measure indicate the plans 
to which each measure applies - Flexible Response Plan (FRP) , 
Immobilization Plan (IP) , or Onsite Disposal Plan (ODP) . 

I . Topography, Geology, and Soils 

Keep Ponds Wet Prior to Flooding (FRP, IP) . To prevent an 
initial flushing of selenium from soils at Kesterson Reservoir 
into groundwater when Ponds 1-5 and 7 are flooded with clean 
water, the ponds have not been allowed to dry completely. 
Sufficient water will be maintained in these ponds so that the 
soils will not dry before clean water is added. 

Reduce Volume of Excavated Soils (ODP) . Excavation will be 
limited to sediments which are >^4 mg/kg selenium. This will 
minimize the less-than-signif leant impacts of wind erosion and 
compaction. Removal of these soils only will also mitigate 
construction impacts that could have resulted from excavating a 
large soil volume. The volume of soils excavated will be re- 
duced from 1,000,000 cubic yards to approximately 450,000 cubic 
yards (including vegetation). 

Design Landfill to Meet Subchapter 15 Requirements (ODP) . 
To minimize the risk of geologic damage to the synthetic liner 
of the landfill, the landfill will be designed according to the 
requirements of Subchapter 15 (Title 23, California Administra- 
tive Code) . 

Avoid Excavation at Gallo Property (ODP) . The Gallo prop- 
erty is no longer proposed to be excavated to provide cover 
material for the entire Reservoir following excavation. This 
will reduce soil productivity and wind erosion impacts at the 
Gallo site. Instead, topsoil for the landfill cover will be 
obtained onsite. 



II . Air Quality 

Dampen Work Area Soils to Reduce Dust (ODP) . To reduce 
particulate and selenium air quality impacts from excavation, 
construction, and topsoil importation activity, water will be 
applied to soils at work areas. 



3-30 



Reduce Volume of Excavated Soils (ODP) . Excavation will be 
limited to 450,000 cubic yards of soils and vegetation. This 
will reduce particulate air quality impacts (see Topography, 
Geology, and Soils section, above). 

Avoid Excavation at Gallo Property (ODP) , The Gallo prop- 
erty is no longer proposed as a source to provide cover material 
for the entire Reservoir following excavation. This will reduce 
particulate emission impacts. Instead, topsoil for the landfill 
cover will be obtained onsite rather than from the Gallo prop- 
erty (see Topography, Geology, and Soils section, above) . 



III . Noise 

Use Mufflers on Harvesters (IP) . To reduce noise impacts 
resulting from the operation of harvesting equipment used to 
excavate the vegetation in the southern ponds, factory-equipped 
mufflers or other sound suppression devices will be maintained 
on all such equipment. 

Use Mufflers on Heavy Equipment (FRP, IP, ODP) . If offsite 
mitigation wetlands are developed, factory-equipped mufflers or 
other sound suppression devices will be maintained on all con- 
struction equipment. 

Limit Harvest Activity to 8 Hours Per Day (IP) . To miti- 
gate for noise impacts to residents living near or adjacent to 
Kesterson Reservoir, vegetation harvesting activity will be 
limited to an 8-hour period during the daylight hours. 

Avoid Excavation at Gallo Property (ODP) . The Gallo prop- 
erty is no longer proposed as a source of cover material for the 
entire Reservoir following excavation. This will reduce noise 
impacts resulting from hauling soils from the Gallo property 
(see Topography, Geology, and Soils section, above) . 

IV. Groundwater 

Keep Ponds Wet Prior to Flooding (FRP, IP) . See Topogra- 
phy, Geology, and Soils section, above. 

Reduce Volume of Extracted Groundwater (FRP, IP, ODP) . To 
reduce the drawdown impacts of the extraction well network, the 
volume of groundwater extracted will reflect only the amount 
necessary to remove selenium-contaminated groundwater. 

Refine Extraction Well Network Design to Reduce Drawdown 
(FRP, IP, ODP) . Details of the groundwater extraction program 
are provided in the Final EIS description of the proposed action 
(see Chapter 2, Groundwater Monitoring section of FRP). The 
areal extent of groundwater contamination varies considerably. 
The results of ongoing studies will enable the USER to design 



3-31 



its extraction program so that areas of contaminated groundwater 
can be removed without causing unnecessary drawdown. 



V. Surface Water 

Keep Ponds Wet Prior to Flooding (FRP, IP) . See Topogra- 
phy, Geology, and Soils section, above. 

Use Local Groundwater Source in Lieu of CVP Water (FRP, 
IP) . To reduce any risks of surface water contamination result- 
Trig from CVP water conveyance through an unexcavated SLD, local 
well water supplies will be used as a water supply for the FRP 
and Immobilization Plan. 



VI . Vegetation 

Select Another Alternative if Contamination Continues (FRP, 
IP) . The proposed action is designed to allow continued study, 
evaluation, and selection of methods to clean up the contamina- 
tion at Kesterson Reservoir in the event that monitoring indi- 
cates the FRP or Immobilization Plan will not succeed in achiev- 
ing selenium reduction goals. 

Implement Nuisance Abatement Program (Short-Term Mitiga- 
tion) (FRP, IP, ODP) . For each plan, specific action will be 
taken to reduce exposure of vegetation, fish, and wildlife 
resources to conteimination at Kesterson Reservoir during the 
cleanup process, and to compensate for any continuing exposure 
that is not avoided. These actions are discussed in the Final 
EIS description of the proposed action (see Chapter 2) . 

Provide Long-Term Mitigation to Recreate Reservoir and SLD 
Habitat Values that Existed Prior to Contamination (FRP, IP, 
ODP) . The DOI IS considering a number of measures that could 
recreate the habitat values provided by Kesterson Reservoir and 
the SLD prior to its contamination by subsurface agricultural 
drainage. These measures are discussed in the Final EIS de- 
scription of the proposed action (see Chapter 2) . 

Control SLD Vegetation as Necessary (FRP, IP, ODP) . If 
substantial vegetation growth occurs in the SLD causing risks of 
selenium mobilization or food chain impacts, USER will use 
appropriate physical or chemical means to control SLD vegeta- 
tion. 



VII . Fisheries 

Establish Fisheries in Offsite Mitigation Wetlands (FRP, 
IP, ODP) . If offsite mitigation wetlands are developed, fisher- 
ies may be established as determined appropriate in consultation 
with USFWS. 



3-32 



Do Not Restock Fish in Kesterson Reservoir Unless Selenium 
Contamination Eliminated (FRP, IP) . To minimize contamination 
risks, restocking of fish species would occur in Kesterson 
Reservoir only when selenium levels in the water are £5 pg/l 
(USFWS recommends 2 ug/1) and background levels of selenium in 
benthic invertebrates, plankton, and insects are <^5 mg/kg (dry 
weight) . 



VIII. Wildlife 

Select Another Alternative if Contamination Continues (FRP, 
IP) . See Vegetation section, above. 

Implement Nuisance Abatement Program (Short-Term Mitiga- 
tion) (FRP, IP, ODP) . See Vegetation section, above. 

Provide Long-Term Mitigation to Recreate Reservoir and SLD 
Habitat Values that Existed Prior to Contamination (FRP, IP, 
ODP) . See Vegetation section, above. 

Control SLD Vegetation as Necessary (FRP, IP, ODP) . See 
Vegetation section, above. 

IX. Land Use 

Implement Nuisance Abatement Program (Short-Term Mitiga- 
tion) (FRP, IP, ODP) . See Vegetation section, above. 

Provide Long-Term Mitigation to Recreate Reservoir Habitat 
Values that Existed Prior to Contamination (FRP, IP, ODP) . See 
Vegetation section, above. 

X. Population, Housing, and Social Environment 

Purchase of Appropriate Surrounding Private Lands (FRP, IP, 
ODP) . The purchase of appropriate surrounding private lands 
will be considered if it is later determined that the influence 
of Kesterson Reservoir on groundwater is adversely affecting 
such lands to an extent that justifies such action, or if other 
programmatic purposes justify this action. This action would 
also further mitigate any quality of life impacts caused by 
cleanup activities, such as hazing and construction noise, dust, 
and traffic. 

Implement Noise Mitigation Measures (FRP, IP, ODP) . See 
Noise section, above. 

Keep Public Informed of Kesterson Program Activities (FRP, 
IP, ODP) . Residents near Kesterson Reservoir and the SLD will 
be informed of monitoring results and cleanup decisions through 
mechanisms such as aruiual press releases and limited direct 
mailings . 

3-33 



XI. Public Health 

Continue Hazing as Necessary (FRP, IP, ODP) . To reduce the 
risk of human consumption of contaminated wildlife, the hazing 
program will be continued as long as necessary, as indicated by 
biological monitoring. 

Continue Public Awareness Program (FRP, IP, ODP) . To 
minimize risks from human consumption of contaminated wildlife 
from Kesterson Reservoir and the SLD, public awareness measures 
such as warning posters and the issuance of health advisories 
will continue. These measures are discussed in the Final EIS 
description of the proposed action (see Chapter 2) . 

Implement Air Quality Mitigation Measures (ODP) . See Air 
Quality section, above. 

Use Protective Breathing Devices and Monitor Personal Air 
Quality During Excavation (ODP) . To protect workers from expo- 
sure to particulates, protective breathing devices will be worn 
if particulate levels during excavation exceed 15 mg/m . 

Reduce Volume of Excavated Soils (ODP) . Excavation will be 
limited to 450,000 cubic yards of soils and vegetation. This 
will reduce worker exposure to particulate contaminants. See 
Topography, Geology, and Soils section, above. 

XII . Recreation and Transportation 

Provide Recreation at Off site Mitigation Wetlands (FRP, IP, 
ODP) . To reduce recreation impacts from restricted access at 
Kesterson Reservoir, public recreation will be allowed if off- 
site mitigation lands are developed. 

Avoid Importation of Soil From the Gallo Property (ODP) . 
Soil importation from the Gallo Property will not occur, reduc- 
ing transportation impacts along Highway 165. 

XIII. Energy 

Reduce Volume of Excavated Soils (ODP) . Excavation will be 
limited to 450,000 cubic yards of soils and vegetation. This 
will reduce fuel consumption resulting from excavation. See 
Topography, Geology, and Soils section, above. 

Avoid Importation of Soil from Gallo Property (ODP) . 
Because topsoil from the Gallo property will not be applied to 
Kesterson Reservoir following excavation, fuel consumption from 
topsoil hauling will be limited to hauling onsite topsoil needed 
to provide a landfill cover. 



3-34 



XiV. Cultural Resources 

Consult with the State Historic Preservation Officer (SHPO) 
and Implement Recommended Mitigations (FRF, IP, ODP) . Consulta- 
tion with the SHPO will occur, and appropriate mitigation mea- 
sures will be implemented, if the Onsite Disposal Plan is imple- 
mented, or if offsite mitigation wetlands are developed. 



3-35 



I 

I 
I 
I 



3-36 



I 

i 

i 

fl 



Chapter 4 



ERRATA TO DRAFT 
ENVIRONMENTAL IMPACT STATEMENT 



This section describes corrections that have been made to 
the Draft EIS (Volume II of the Final EIS) . Underlining indi- 
cates where changes were made to the original text (except where 
underlining is used to identify subject headings or scientific 
names) . Strike-outs indicate where the original text is 
deleted. 



Page iii, para 1, line 5: "... into the groundwater in iseiated 
some locations ...." 



Page 1-2, last para, line 5: "... determined that m©st--o€ the 
selenium came from irrigated agricultural areas, 



It 



Page 1-3, para 1, line 2: "... (ehieRd©i?€--et — a-t. — ±n--p¥^ss — a-; 
USBRj; USBRa; Saiki i985 1986 ) ..." 

Page 3-5, para 4, line 2: "... most observations are less than 
the pjfeiiR'.inajfy-heaith--g-e>e-l — (-&eeept-ebi«--eH:wHje-l--<ie-i-ly--irR-ba-ke->--of 
i9&-ti-gV4--9e4^-b-y--BPA--£'er--d«riTiY--i-ftta-k«--©-£--dr^-«k-d-«g^ listed 
Estimated Permissible Ambient Goal of 70 pg/1 cited by RWQCB to 
protect human health . " 

Page 3-5, para 6, line 5: Before "This is a conservative ap- 
proach, ..." insert the sentence, " Low concentrations refer to 
levels near the analytical detection limit where a majority of 
the analyses were below detection . " 

Page 3-7, para 2, line 4: "There are iaeiafeed some areas where 
selenium has migrated ..." 

Page 3-8, para 3, line 3: "... there are iseiafeed some areas 
where . . . . " 

Page 4A-1, para 1, line 8: "... layer for the aaffeesian regional 
aquifer system ...." 

Page 4A-1 , para 1, line 11: "... 239 180 feet beneath " 

Page 4A-3, para 3, line 4: "... (EC), an measare indicator of 
salinity . . . . " 

Page 4A-5, para 7, line 3: "... 62-mile stretch of the drain 
(USBR 19851) ." 



4-1 



Figure 4-8, following Page 4A-22: "NOTE: For example, volume of 
soil with <5 mg/kg selenium would be 700,000 cy; since the total 
volume of soil (0- to 6-inch depth) is about 1,000,000 cy , then, 
by difference, the volume of soil with 5 mg/kg selenium would be 
about 3 00,000 cy . " 

Page 4B-9, Table 4-9, note "a": "... compound ( immediately south 
of Pond 6 and west of Pond 4) . 

Page 4B-9, Table 4-9, note "b" : "... Drain Check 1 ( adjacent to 
the southeast corner of Pond 5) . 

Page 4B-20, para 2, line 6: "... steek stack gas temperature may 
should be less than the assumed 1,500°F. Additional dispersion 
modeling may will be required ...." 

Page 4D-7: For copper, the number of observations exceeding the 
84.6 pg/1 criterion is 3, not 5. For molybdenum, the number of 
observations exceeding the 70 pg/1 criterion is 173, not 177. 
For nickel, the most stringent criterion is 160 pg/1, and the 
number of observations exceeding this criterion is 4; no other 
criteria for nickel are applicable. 

Page 4D-11, para 6, line 2: " . . . (USBRea) . . . " 

Page 4D-16, para 1, line 5: "... Based on this gradient and 
data-pifesented-in-Tabie-^-aOT an estimate of the lateral ground- 
water velocity ..." 

Page 4D-17, para 6, line 6: "... The available selenium could 
abserb adsorb on ferric oxyhydroxides ..." 

Page 4E-5 , para 5, line 1: "Presently available data show that 
the beneficial uses are generally not inhibited in the waters 
surrounding Kesterson Reservoir and the SLD, with the exception 
of fisheries and wildlife habitat . " 

Page 4E-11, para 2, line 1: "... Concentrations of molybdenum 
in Salt Slough seidem-exeeeded-the-petentiai-wateif-qttaiity-iimit 
f©jr-*4^«--pi?ot:eetri-oft--crf--«Kj«€rt^ii3--tirfe--tiQ-ppM did not exceed the 
estimated permissible ambient criterion of 70 pg/1. Influences 
from mixing with natural runoff and high groundwater tables in 
the vicinity of the Gallo property e©«id would lower the molyb- 
denum levels te-beiew-ie-ppbr ..." 

Page 4F-14, para 1, line 3: "At Volta Wildlife Area, an uncon- 
taminated wetland near Kesterson NWR, Saiki -fin-pires-s-)- found an 
aveifage e€ GtB ppi« seieniam -fi"ange---ttndeteetabie-te-6Te-ppm)- in 
iB sampiea ©f aqaatie piantsy ineiading sag© p©ndweed -f-sier^-- 
tapegifass -f-sicT^- and water miifeii -f Myg±ephy3:J:Bm -9pT)-T Jones 6 
Stokes Asseeiatea f©Hnd an average of 3 ppm seieniem -fjrange--= 
i-iif in ie aampies of eattaii- aikaii bttiifushy and sait grass 



4-2 



eeiieeted at Veifea Wiidii^e Ai?ea in January i986T ( 1986) found 
an average of 0.495 ppm selenium dry weight (range = undetect- 
able to 0.79 ppm) in 10 samples of submerged aquatic plants, 
including sago pondweed (Potamogeton pectinatus) , water milfoil 
(Myriophyllum sp.), and unidentified plant (probably bur-reed, 
Sparganium sp.)." 

Page 4F-14, para 2, line 7: "In 33 samples of wigeen-gjfaas and 
heened pendweedy submerged plants (wigeon-grass and horned- 
pondweed) collected from Kesterson Reservoir and the SLD in 
1983 , Saiki i±n ptepT)- ( 1986 ) found an average of ?5 73^ ppm 
selenium dry weight (range = 18-390 ppm)." 



Page 4F-15, para 4, line 2: "... concentrations in vegetation is 
are much higher throughout Kesterson . 



II 



Page 4G-1, para 1, line 8: "... (Saiki i985 1986 ) ..." 

Page 4G-2 , para 1, line 2: "6fcHdie9-*>y--&ditet---f3r9-&5-)---i«'d-ie-a't«d 
that ave^fage-■s•ei■et^i■t^ffi-<^orteefrt^J?tH^iofte — i-n--ii9h--e©4.-l-ee-t-ed — a^ — S-*tt 

Gieagh — i-n---]r9^M---wei?e — i-.i — ppw — we-t---we-ight-. A-v-ei:-a-g« — seienium 

eeneentJ?atiens-in-'#i9h-e©iieeted-at-MHd-Si©«gh-in-i984-weife 
3Te-ppm-wet-weight--fSaiki-i986)-T Selenium concentrations ranged 
from 0.62 to 1.5 ppm wet weight in fish collected from Salt 
Slough. Selenium concentrations in fish collected from Mud 
Slough in 1984 ranged from 1.3 to 5.5 ppm wet weight (Saiki 
1986) ..." 

Page 4G-2, para 2, line 1: "Fish samples from the San Joaquin 
River near Hills Ferry Road contained ©-rB-ppm 0.18-1.4 ppm 
selenium wet weight, and fish collected from Suisun Bay 
eentained--aii--aves'age-of — e-r4--ppm ranged from 0.29 to 0.51 ppm 
selenium wet weight (Saiki 1986)." 

Page 4G-2 , para 4, line 4: "... concentrations of less than 
0.2 ppm wet weight ( Volz pers. comm .)." 

Page 4G-2 , para 7, line 5: "Samples from all areas were analyzed 
for arsenic, boron, cadmium, chromium, copper, mercury, nickel, 
lead, selenium, and--ebotrt: — 2-e---e>r-g-efi-©e+i-l-e«--i-d-e — pee^ie-ide«---(Said± 
1986)- and zinc, whereas only samples from the Reservoir and SLD 
were analyzed for 23 organochlorine residues (Saiki 1986) . . . . " 

Page 4G-3 , para 1, line 1: "... (Saiki i985 1986 ) ..." 

Page 4G-3 , para 1, line 3: "... (roughly i35 K^ ppm dry 
weight) , ..." 

Page 4G-3 , para 1, line 5: "e©neenti?atien9-©i-etheif-eiement9-and 
pes tie ides -weif«—»iin>i-l-©* — if^-§-ir9-h--#3?©m-th€-H:-wo--s-i-fces-. Only two 
organochlorine residues — p.p'-DDE and Aroclor 1254 — were 
detected in fish from the Reservoir and the SLD, and both 
residues were at low concentrations (0.06 ppm wet weight) . . . . " 



4-3 



Page 4G-3, para 1, line 6: "Meaqtiitef ish-^■r■©^n--Ke•^^^el'^on--He«e-r- 
v©i^f-eente±ned-aR-averttge-ef-3:?6-and-^&e-ppm-^eieRi«m-dey weight 
in — -y^^2r--€tn^ — i9£4- — i^espe-efcirvel-y Mosquitofish collected from 
Kesterson Reservoir in 1983 and 1984 contained the following 
levels of selenium: 



Geometric Means of Selenium (ppm dry weight) 

Kesterson Pond 1983 1984 

2 22_4 3^ 

7 Not analyzed 188 

8 16_4 3_40 
11 132 108 



Source : Ohlendorf (April 26, 1985b) pers. comm, 



Page 4H-5, para 2, line 3: "A mixed colony of snowy egrets and 
black-crowned night-herons has periodically nested in emergent 
vegetation at Sprig Lake, bttt-appaifefltiy-fl«*--s-i-t=i«« — 1-9-8-4 and the 
night-herons also nested there in 1986 (Zahm pers. comm.) . . . . " 

Page 4H-7, para 4, line 1: "... aii most bird species ..." 

Page 4H-11, para 5, line 3: "... the occurrence of endangered 
federally- lis ted and candidate species ..." 

Page 4H-11, para 5, line 4: "... endanges-ed — and- - -eetwi-irda-be 
speeies federally-listed and candidate species ..." 

Page 4H-12, para 5, line 3: "Feai? t'ive of these species (San 
Joaquin kit fox, Fresno kangaroo rat, bald eagle, peregrine 
falcon , and blunt-nosed leopard lizard ..." 

Page 4H-12, para 6, line 5: "... (Saiki i985 1986 ) " 

Page 4H-15, para 5, line 5: "... Saiki (ttnpHbiiahed-'d-a-t-a pers. 
comm. ) reported the following preliminary results for 
invertebrates collected in August 1983 from the SLD; a mean of 
ifeST© 160 ppm selenium dry weight for damselfly nymphs and 203t8 
284 ppm selenium ..." 

Page 4H-17, para 3, line 10: "Selenium concentrations in livers 
of ducks collected at the Reservoir in 1983 averaged 26T6--ppjn 
di?y--weight — ^hrieft<io-jf-f--e't--a-K — irft--pr-es-s — a-) 19.9 ppm dry weight 
(Presser and Ohlendorf in prep.) . . . . " 



4-4 



Page 4H-17, para 4, lines 9-12: "... hatching at Volta VJildlife 
Area in i986 1983-1985 . Nests studies included those of 
pied-billed grebes, killdeer , mallards ..." 

Page 4H-19, para 2, line 7: "No coots nested at the Reservoir in 
1984 or 1985 (Ohlendorf et-ai-r-iR-press-b pers . comm. b ) ...." 

Page 4K-21, Table 4-45, house mouse selenium concentrations (ppm 
dry weight), Kesterson Reservoir: "Pond 5 i4-^ 4 . 17 ..." 

Page 4H-22, para 4, line 9: "... natural selenium were ir^GG-ppb 
1 . 4 ppm - . . and 3-©96-ppb 3 . ppm ..." 



Page 4H-2 5, para 3, line 7: "Some migratory waterfov;! weaid 
pjfebabiy will be attracted to these ponds 



II 



Page 4N-2, para 4, line 3: " The results of ene a USDA study has 
been — done on selenium levels in selected agricultural crops 
grown along the SLD iHe^fman-pefST-eeflm--)--: — ■€4=ie--i?e«ti-l-t-9--o-f — th-i-s 
study did not indicate excessive seleniiam concentrations; 
however, iabe3fateify--^]?eeed«-£'e3--^-or--'t.he'se--da-fca — eH?e---et]-«?ettt-ly 
Hndej?--if'ev-i-ew — 5oi? — v-a-i-iis-i-fe-y these data may not be representative 
of the entire area (Hoffman pers. comm.) . 

Page 4N-3, para 2, line 5: "... United States drinking water 
supplies generally range ..." 

Page 4N-3, para 4, line 3: "... (EPA i986 19 8 4 ); ..." 

Page 4N-4, para 2, line 5: "... 1983. Other research has sug- 
gested that safe levels of selenium has protective effects 
against coronary heart disease and cancer (EPA 1980a) . and The 
texieifey toxic effects of other elements such as arsenic, cad- 
mium, mercury, and certain pesticides have been shown to be 
lessened in animals from intake of safe levels of selenium (EPA 
1980a) ." 

Page 4N-6, para 3, line 4: "... collected from the Kesterson 
Reservoir in 1985 had ..." 

Page 4N-8, para 1, line 4: "... The review committee found no 
evidence to indicate any aeate texie effect adverse health 
effects on area residents ...." 

Page 4N-9 , para 5, line 3: "... (EPA 1985b) ...." 

Page 4N-15, para 7, line 2: "... Four of these wells are down- 
gradient (wells 1-4, Figure 4-11) ; 10 are upgradient (wells 
5-14, Figure 4-11) and separated ..." 

Page 4N-16, para 6, line 2: "... ducks collected by the DFG 
•fi984-86)- in 1985 ..." 



4-5 



Page 9-12, follows para 10: Insert the following literature 
citation: 

"Saik i, M.K. 1984. Environmental conditions and fish faunas in 
low elevation rivers on the irrigated San Joaquin Valley 
floor, California. Calif. Fish and Game 70 (3) : 145-157 . " 

Page 9-12, para 11: The following reference, which was still in 
draft form when the DEIS was prepared, should be amended as: 

"Saiki , M. K. 1986. A field example of selenium contamination 
in a n aquatic food chain. First annual environmental sympos- 
ium; "selenium in the environment; proceedings. Calif. Agric« 
Tech. I n st., Publ. No. CATl/860201 ; 67-76 . " 

Page 9-18, para 4: The following reference, which was unpublish- 
ed when the DEIS was prepared, should be amended as: 

Wilson, C. J. and G. Tchobanoglous . i986. 1986 . The role of 
wetlands in the removal of selenium from subsurface agricul- 
tural drainage. Pp. 137-148 in Sym.posium on Selenium in the 
Environment, California State University, Fresno, CA, 
June 10-12, 1985. (CATI-86021) . California Agricultural 
Technology Institute. Fresno, CA. 

Page 9-20, para 10: The following personal communication should 
be amended to: 

"Ohlendorf, H. M. Beeembef- 4-9-8-5- -*rKi--iJaft«tiify- — Fet>3?ii©i?y--t9'8-&a. 
February 20, 1986. Research Biologist/Leader. Pacific Coast 
Field Station, Patuxent Wildlife Research Center, U. S. Fish 
and Wildlife Service, Bixeny Davis , CA. Meetings-'ei'^d — -fce-te— 
pheRe--et>f>vei:>s©t-i-o«-: M emorandum to Steve Moore, Coordinator, 
San Joaquin Valley Drainage Program, U. S. Fish and Wildlife 
Service, Sacramento, CA. " 

Page 9-21, para 13, line 1: Insert the following personal 
coinmunication : 



VO 


Iz, M. G 


October 


29 


, 1985. 


Environmental 


biochemist 


, group 


1( 


Bader /environmental 




measurements . 


Department 


of 


Health 


S( 


Brvices , 


Berkeley, 


Ca 


lifornia 


. Lett 


er and 


unpubl 


ished 


data." 



p 
i 



4-6 



Chapter 5 



RESPONSES TO COMMENTS RECEIVED ON THE DRAFT 
ENVIRONMENTAL IMPACT STATEMENT 



Agencies and Individuals Commenting in Writing on the 
Draft Environmental Impact Statement 



Federal Agencies 

Bureau of Indian Affairs 

Bureau of Land Management 

U. S. Fish and Wildlife Service 

U. S. Geological Survey 

U. S. Army Corps of Engineers 

U. S. Environmental Protection Agency 



Page 

5-4 

5-6 

5-8 

5-40 

5-68 

5-70 



State Agencies 

Honorable Rusty Areias (State Assemblyman) 
California Department of Fish and Game 
California Department of Health Services 

California Office of Historic Preservation 

California Resources Agency 

California Regional Water Quality Control Board, 

Central Valley Region 
State Water Resources Control Board 



5- 


-85 


5- 


-88 


5- 


-93 and 


5- 


-95 


5- 


-104 


5- 


-106 


5- 


-108 


5- 


-114 



Local Agencies 

City of Gustine 

Contra Costa Water District 

Fresno County Public Works and Development Services 

Department 
Kern County Department of Planning and Development 

Services 
Merced County Counsel 
Merced County Health Department 



5-117 
5-123 

5-126 

5-133 
5-135 
5-136 



Other Agencies and Organizations 

California Waterfowl Association 
Chapman Forestry Foundation 
Defenders of Wildlife 



5-140 
5-145 
5-147 



5-1 



other Agencies and Organizations (Continued) Page I 

Environmental Defense Fund 5-152 

Land Preservation Association 5-157 S 

National Audubon Society 5-161 r 

Natural Resources Defense Council 5-164 

Red Tape Abatement, Ltd. 5-186 

Sierra Club of California 5-191 

Individuals 

David R. Dawdy 5-200 

Doris Ostrander Dawdy 5-209 

Alice Q. Howard 5-218 

Jeff Kerry 5-221 

Ivan H. Roscoe 5-223 

Ferdinand S. Ruth 5-225 

Jan Whittington 5-227 



5-2 



Comments and Responses 



5-3 



ATTN or : 



May 6, 1986 

Chief, Environmental Services Staff 



UNITED STATES GOVEKNMlNT 

memorandum 



Draft Environmental Impact Statement — Kesterson Program, Merced and 
Fresno Counties, California (DES 86/21) 

Sacramento Area Office 
Attn: Don Knapp 

Provide comments as outlined In the attachment by June 30, 1986. 

A copy of these comments should be provided to the Environmental 

Services Staff, Code 204. 




Attachment 



Kmo wwan lands under the jurisdiction 
of this office are involved 



D NO COMMENT* 

BUREAU OF 
2800 r- 

D" 



>ACRAMENTO /^o^A OFFICC 
,n r^i' -,825 




5-4 



o^Tto*^AL rowM ►♦o to 
csA F-PMR (4; cr»; iot-iit 



i 



Response to Comments of the Bureau of Indian Affairs (BIA) 
1. The USER appreciates the BIA's review. 



5-5 




IN REPLY REFER TO: 



United States Department of the Interior 

BUREAU OF LAND MANAGEMENT 
CALIFORNIA STATE OFFICE 

2800 Conage Way 
Sacramento, California 95825 



1792 

CA-930 



12 



Memorandum 



To: 



From: 



Director, Office of Environmental AfEdtrs, Bureau 
of Reclamation 

Deputy State Director, Lands & Renewable Resources 



Subject: DEIS Kesterson Program, Merced and Fresno Counties, CA 

We have reviewed the subject document and conclude there would 
be no impacts to lands administered by this agency. One of 
our primary concerns is disposal of waste material from 
Kesterson on public lands. However, the alternatives involving 
material removal from the project area all indicate use of 
existing class I or II disposal sites on private land. 



The opportunity to comment is appreciated. 




cc: 

DM, Bakersfield 

WO (760) , Room 909 Premier 

USER (Susan Hoffman) 



Bldg. 



5-6 



Response to Comments of the Bureau of Land Management 

1. The USER concurs with this assessment. There will be no 
disposal of waste materials on BLM administered lands under 
any of the alternatives evaluated as part of the Kesterson 
Program. 



5-7 




United States 

Department of the Interior 



Fish and Wildlife Service 

Lloyd 500 Building, Suite 1692 
500 N.E. Multnomah Street 
Portland, Oregon 97232 



In Reply Refer To: 



July 8, 198* 



Memorandum 



To: 



Regional Director, Bureau of Reclamation, 
Mid-Pacific Region, Sacramento, California 



.«*: 



From: ^<^'' Regional Director, Fish &. Wildlife Service, 
Portland, Oregon 



Subject: Review of Draft Environmental Impact Statement (DtlSj 
on the Kesterson Program 



The Fish and Wildlife Service (Service) has reviewed the subject 
document and offers the following comments for your use and 
consideration when preparing the final EIS. 



GENERAL COMMENTS 



The Service, as a cooperating Federal agency in the preparation 
of the EIS, has provided input to the Bureau of Reclamation (Bur- 
eau) relating to resources under our stewardship. These resour- 
ces include the Kesterson National Wildlife Refuge (NWR), migra- 
tory birds and their habitat, federally listed, proposed, and 
candidate species, public use on the refuge, and anadromous fish. 
Review comments on the preliminary DEIS were transmitted on March 
4, 1986. 



Our major concerns regarding the DEIS include: elements of the 
phased proposed action, the unacceptable level of risk to the 
above-listed biological resources if the "wet phases" of the pro- 
posed action were to be implemented without acceptable measures 
being taken to eliminate exposure of these resources to toxic 
elements, and the need for interim and long-term mitigation for 
the physical loss of habitat and the loss of the value and use of 
habitat. These concerns also relate to possible effects of 
cleanup and restoration actions on the federally listed endan- 
gered San Joaquin kit fox and the Bureau's obligation under the 
endangered Species Act of 1973, as amended. 

RaTiionale supporting the proposed action appears to be based on 
incomplete or unavailable information regarding effecxs of leav- 
ing selenium-contaminated Kesterson Reservoir and San Luis Drain 
(SLD) soils, sediments, and vegetation in place. The Service has 



5-! 



independently developed an environmentally preferable alternative 
for your consideration which minimizes risks of elevated selenium 
levels to onsite biological resources. This alternative should 
be incorporated into the Record of Decision (40 CFR 1505.2(b)) 
for this project. 



Under provisions of the Fish and Wildlife Coordination Act, the 
Service provided a Kesterson Cleanup Program Restoration/Mitiga- 
tion Analysis Planning Aid Letter (PAL) to the Bureau on January 
13, 1986. The PAL is not appended to the DEIS. The Bureau has, 
however, incorporated these prior Service recommendations and 
editorial comments into the DEIS text. An updated PAL related to 
the selected alternative will be developed and transmitted to the 
Bureau. 



A Biological Assessment addressing distribution and possible 
effects of proposed cleanup options on federally listed endan- 
gered and candidate species is in the process of being developed 
for this project. The subject Biological Assessment report 
should be completed and a well-defined proposed action identified 
and clearly outlined prior to initiation of formal consultation 
on this project. The Service has up to 90 days to render a 
subsequent Biological Opinion on this project as part of the 
formal consultation process. The Biological Opinion should be 
appended to the FEIS. 



SPECIFIC COMMENTS 

Detailed specific comments for inclusion into the "errata" sec- 
tion of the FEIS will be provided to the Bureau directly from our 
staff in Sacramento. 



Proposed Action 

In review of the DEIS for the cleanup of Kesterson Reservoir and 
the SLD, the Service has identified a number of concerns regard- 
ing the proposed action. 

Regardless of the alternative chosen for implementation, the Ser- 
vice believes that the February 1988 deadline should be met. 
Furthermore, it is the position of the Service that an action 
should be implemented by March 1987 to demonstrate and assure 
that the abatement of nuisance conditions to fish and wildlife 
resources (i.e., zero death and deformity of fish and wildlife 
from contaminants) will be achieved at Kesterson Reservoir by 
February 1988. 



5-9 



A major Service concern is the selection of the Flexible Response I 
Plan-Wet option (wet-flsx) and the Immobilization Plan-pond 
option by the Bureau as proposed action phases. The DEIS states 
on pages 4H-39 and 40 and on page xxiv of the DEIS Summary that I 
neither of these actions would eliminate potentially significant ' 
risks to fish and wildlife resources. We believe that these two 
alternatives would be likely to have unacceptable consequences to | 
biological resources. Hazing, which has had variable success as f 
an interim protection measure, would have to be continued indefi- 
nitely. Elimination of fish and wildlife death and deformities 
due to the contamination of the food chain at the Reservoir does 
not appear to be foreseeable under these alternatives. We be- 
lieve that the proposed action is based on incomplete and unavai- 
lable information regarding the unknown effects of selenium- 
contaminated Kesterson Reservoir-SLD soils, sediments, and 
vegetation if left in place. 

Research by- the Service and that discussed in available litera- 
ture has not demonstrated that selenium-contaminated soils, sedi- 
ments, and "harvested vegetation" overlain by low selenium or 
selenium-free water would create a contaminant-risk-free environ- 
ment for fish and wildlife resources. Various rooted marsh 
plants, benthic (including burrowing) animals, and aquatic ani- 
mals that forage on benthic prey would be expected to use the 
Reservoir following "cleanup." For example, bottom-feeding fish 
would be expected to colonize the Reservoir; with the change in 
habitat, wading birds would be expected to increase use in the 
Reservoir; and shorebirds (e.g., stilts and avocets) would be 
expected to continue to use the Reservoir. Information available 
in the scientific literature on the biology of these plants and 
animals strongly suggests that they would accumulate and recycle 
contaminants that are present in soils and sediments. 

We have the following concerns regarding DEIS discussions of the 
wet-flex and immobilization-pond cleanup options: 

A . Biological Factors 

1. We do not believe that geochemical models that do not 
address important biological cycling processes are of 
value in mitigating potential toxicity or suggesting 
valid treatment or cleanup options. Generation of 
biologically available forms of selenium from particu- 
late organic matter and elemental selenium in benthic 
sediments proceeds, to a large extent, via catalytic 
and microbial pathways which are not accounted for in 
geochemical models. Most organic carbon in an aquatic 
system moves through the detrital pathway via macro- 
invertebrate processing and/or bacterial processing. 
Bacteria have been identified that oxidize elemental 
selenium to selenite. Aquatic bacteria readily ac- 
cumulate selenium to high levels, sometimes higher 
than in mosqui tof ish. 



3 

5-10 



i 

P 



10 

11 

12 



13 



14 



15 



2. We believe that the DEIS description and analysis 

of Kesterson Reservoir biota and associated chemical/ 
physical conditions across time and habitats are in- 
sufficient . 

3. The DEIS does not discuss important detrital pathways 
for selenium cycling and biological mobilization that 
would occur even if sediments could be kept uniformly 
anaerobic across all habitats/seasons (bioturbation, 
microbial mobilization, etc.). 

4. Direct use of sediments by waterfowl and other birds 
and animals is not adequately considered. 

5. Indirect use of sediments by other organisms is not 
adequately considered. 

6. The DEIS assumes that uniform, mono-specific stands of 
Nitella can be maintained across all seasons and habi- 
tats. It does not consider seasonal die-offs. Effects 
of nitrogen and phosphorus additions were not ade- 
quately considered. 

B. Chemical/Physical Factors 

1. Superimposing a geochemical model onto a biological 
system will not work if important biological proces- 
ses are not adequately considered. 

The presence of thermodynaraically unstable selenite in 
anoxic ocean zones confirms the existence of catalytic 
or bacterially mediated selenium speciation. Moreover, 
anoxic conditions near the sediment/water interface of 
the Kesterson Reservoir cells may tend to stabilize 
thermodynamically unstable organic species of selenium 
(i.e., selenomethionine, selenocys t ine , methylated 
selenides, etc.), thereby increasing their residence 
time and their bioavailability. 

2. Physical resuspension is likely to occur due to:a) 
wave action; b) rainfall; and c) seasonal and diurnal 
turnover. All would contribute to aerobic sediments. 

Existing literature and our own experience does not 
support the DEIS assumption that there would be a 
unidirectional flux of selenium into sediments due 
to adsorption/coprecipitation and further chemical 
reduction. 

a) No information is provided on adsorption isotherms 
for various selenium species (i.e., distribution 
coefficients between sediments and water, clay 
rainerology, organic carbon content, and surface 
area of adsorbing surface). 



3. 



5-11 
4 



16 



17 



19 



b) The DEIS considers only inorganic selenium. It is 
our experience that organic selenium may be more 
critical toxicologically. 

4. Chemical/physical principles alone may be appropriate 

to model groundwater cycling and transport of selenium. 
Biological principles must be used when modeling sur- 
face water cycling/ transport of selenium. 

Toxicoloqical Factors 

1. Existing literature and our own experience does not 
support the DEIS implication that the chemical 
reduction of selenium reduces toxicity. 

a) Biological processing/cycling and chemical reduc- 
tion of selenium may lead to increases of 
inorganic/organic selenium species that are much 
more toxic. 

2. Existing literature and our own experience does not 
support the DEIS implication that chemical reduction 
of selenium and its transport to sediments results in 
reduced biological availability. 

a) Selenite can be just as available as and more 
toxic than selenate. 



20 



21 



22 



b) — Compiexation/precipitation of selenium to sedi- 
ments would "fuel" the organo-selenium pathway. 
This is an important relationship in regard to 
bioaccumulation and toxicity to fish and wild- 
life. This could result in greater long-term 
toxicity than if it remained waterborne. 

3. The DEIS provides inadequate consideration of the 
principles of selenium toxici ty/bioaccumulat ion . 

a) Acceptable/unacceptable levels of selenium in 
water/biota in relation to known toxic levels 
were not adequately specified in the DEIS (i.e., 
need for discussion on what levels would be 
achieved under "successful" operation of the 
immobilization plan). 

It is the Service's recommendation that if either the wet-flex or 
immobilization (wet) approaches are undertaken that the Bureau 
implement a plan that: 1) eliminates direct and indirect expo- 
sure of fish and wildlife to selenium and other deleterious 
components of Kesterson evaporation cells; and 2) mitigates for 
the 1,280 wetland acres lost. 



5-12 



23 



We also believe that the potential cost of implementing all three 
phases of the proposed action could be significantly higher than 
implementation of a single, but individually more expensive, ac- 
tion that poses lowered short and long-term risks to fish and 
wildlife resources. This concern is reinforced by the fact that 
the two initial phases of the proposed action (i.e., wet-flex and 
immobilization-pond options) contain significantly greater risks 
to fish and wildlife resources when compared to the third phase 
(the onsite disposal option). 



If the DEIS proposed action were to be implemented, additional 
information should be provided for public review, prior to imple- 
mentation. The following information should be discussed in de- 
tail in the FEIS: 



24 



Criteria, timing, and threshold levels for each phase of 
the proposed action. The FEIS should clearly present a 
time frame for determining effectiveness of phased mea- 
sures, criteria for judging effectiveness relative to 
stated objectives, and respective agency involvements in 
determining the degree of effectiveness. 



25 



B. A monitoring plan for biological resources should be estab- 
lished in the interim period and continue throughout the 
cleanup process. Indicator species and threshold levels 
for contaminants should also be identified. 



C. A detailed description of the final and successful state of 
cleanup of the Reservoir and SLD should be provided. This 
would enable the public to more precisely understand the 
ultimate objectives of cleanup for these resources. 

D. The proposed action should also concisely define the plan, 
details, and timing for SLD cleanup. 

We believe that the current differences between the wet-flex and 
immobilization-pond options are minor and do not justify text 
discussion as discrete cleanup alternatives. This apparent simi- 
larity may be more clearly addressed by defining various sub- 
alternative actions in the FEIS. 

More details and clarification are necessary for a clear under- 
standing of the various subcomponents of the proposed action's 
alternative phases. These areas should be discussed in greater 
detail in the FEIS: 

A. The water depths of the cells and water quality/consti- 
tuents of the water source to be used in the wet-flex and 
immobilization-pond options. 

B. The impacts of using Del ta-Mendota Canal water for both 
options may change the biological components of the Reser- 
voir. The characteristics of the biological changes within 
the Reservoir should be addressed. 



5-13 
6 



31 



32 



33 



34 



C. There are distinctly different environmental conditions ex- 
isting throughout the 12 Reservoir cells. The FEIS should 
include a discussion on whether all cells would be treated 
equally in each phase. If not, further explanation is 
necessary . 

The Service also has concerns with the third phase of the 
proposed action, the Onsi te-Disposal alternative, including: 

A. In order to place a disposal facility within a NWR, the 
Service would have to develop a compatibility statement, 

B. We are concerned that the disposal facility as preliminarily 
designed in the DEIS may be more likely to fail than would 

a disposal facility that would be double-lined and capped, 
cover a larger surface area, and not be as high as the fac- 
ility defined in the DEIS. If a disposal facility should 
be developed at or nearby Kesterson Reservoir, we emphasize 
the need for state-of-the-art design and a "fail-safe'' 
system . 

Environmentally Preferable Alternative 

The Service's objective regarding the Kesterson Program is to 
eliminate contaminant hazards to fish and wildlife and to restore 
and replace habitat losses. 

In light of the lack of sufficient data related to the effective- 
ness of various proposed techniques for selenium-contaminant 
cleanup, we have reviewed six different alternative options on 
how to lower potential risks in the Reservoir to resources under 
our legal responsibility. We have developed four criteria to 
evaluate these options: (1) returns Kesterson Reservoir to pre- 
viously defined baseline (1972-1978) habitat values; (2) provides 
acceptable level of both long-term and interim mitigation; (3) 
assures acceptable monitoring program; and (4) lowers or elimi- 
nates risk of contaminant exposure to fish and wildlife resources 
(see Attachment i). 

Under all Reservoir cleanup options, our environmentally prefer- 
able recommendation for cleanup of the SLD is as follows: 



35 



remove all contaminated SLD sediment and vegetation and 
dispose offsite in an environmentally acceptable manner 
(not on Kesterson NWR) 

use of north half of the SLD for conveyance of fresh water 

use of south half of the SLD to be determined 



7 
5-14 



3V| 



The Reservoir cleanup alternative option that we believe would 
have the fewest adverse impacts on fish and wildlife resources, 
and is therefore considered by the Service to be the environmen- 
tally preferable alternative, is as follows: 

- immediately implement interim mitigation (enhancement of 
nearby habitat should be established prior to removal of 
existing emergent vegetation). See discussion under 
"mitigation. " 

allow all cells to go dry 

remove vegetation and top 6 inches of soil (or that amount 
of material that is required to effectively eliminate con- 
taminated soil and vegetation) in an environmentally accep- 
table manner in all 12 cells of the Reservoir and dispose 
of f si te 

mitigate for loss of 1,280 acres of wetland habitat 

- monitor existing plants, animals, and water 

- implement corrective actions, in an environmentally 
acceptable manner, if contamination persists (e.g., 
(1) fill with soil, (2) further removal of soil and 
vegetation, (3) contain, treat, and/or dispose of 
surface/ground water 

We believe that in order to reduce the risk of continued contami- 
nant exposure to fish and wildlife resources, all contaminated 
soil and vegetation should be removed and disposed offsite in an 
environmentally acceptable disposal site. The selection of this 
site should also involve discussions with the Service. The prob- 
ability of liner failure (should selenium-laden soils be stored 
onsite under the "cap option") exists, and we consider the risk 
of further contamination of the NWR to be biologically unaccep- 
table . 

We believe that the risks to resources can be minimized only if 
the contaminated soils, sediments, and vegetation are exported 
from the NWR and the Reservoir cells maintained in a dry state. 
If the cells were flooded following removal of contaminated soil, 
there are insufficient data to support the assumption that selen- 
ium and other contaminants would not continue to impact fish and 
wildlife resources. 

There would be a total loss of existing wetland habitat under our 
environmentally preferable alternative, and therefore, a mitiga- 
tive need for 1,280 acres of replacement wetland habitat. 



5-15 



Mitigation 

The Service generally concurs with the Bureau's plans for mitiga- 
tion for lost habitat and fish and wildlife resource values as 
described in the DEIS. However, there is no discussion of interim 
46 mitigation for impacts that have been ongoing and continue to 
occur at Kesterson Reservoir. Clarification and further details 
are needed in the FEIS in the following areas: 

A. A detailed plan of habitat mitigation or restoration should be 
developed in cooperation with the Service and should include 
the following areas: 

47 

1. water quantity, quality, and management 

2. site design details, and 

3. a timetable for development 

B. Mitigation should be noted to be for "in-kind" habitat and 
value, and should recognize the difference between seasonal 

48 and permanent wetland habitat values and the terrestrial 
habitat values. 

Mitigation is not identified for the no-action alternative. 
Although we recognize that the no-action alternative is 
identified as "unacceptable," the FEIS should state that if 
no actions were taken to clean up the Reservoir and SLD, the 

49 Service would still recommend implementation of mitigative 
measures . 

D. A detailed cost breakdown of mitigation should be provided. 
5Q . It appears that some mitigation components may be overesti- 
mated . 

E. Measures to avoid adverse effects to candidate and endan- 
gered species will be provided in the Service's Biological 

51 Opinion. These measures and implementation costs should 
be discussed in detail in the FEIS. 

In memoranda dated March 4 and April 23, 1986, we requested that 
the Bureau provide interim mitigation for current, ongoing im- 
pacts to fish and wildlife resources at Kesterson Reservoir. 
Although the Bureau has provided alternate habitat through deli- 
vered water supplies on past occasions, a concise plan to ensure 
that mitigation will occur for impacts that are continuing at the 
Reservoir has not been developed. Not only must alternative hab- 
itat be provided for the current situation, mitigative measures 
to provide habitat for tri-colored blackbirds (a candidate spe- 
cies for listing under the Endangered Species Act of 1973, as 
amended), songbirds, waterfowl, and other birds should be 
developed immediately. An alternate site of established wetland 
habitat should be made available for these species prior to the 
removal of existing vegetation. This new habitat could take from 

9 

5-16 



52 



52 



53 



1 to 2 years to develop. A Service memorandum dated June 9, 
1986, provides details of recommended enhancement measures to the 
east side of Kesterson NWR. These measures are outlined in 
Attachment 2. Implementation of these proposals, with an accep- 
table water supply and distribution system, would provide the 
type of mitigative measures necessary to avoid more serious 
impacts to wildlife resources presently using Kesterson Reservoir 
during the interim period and the cleanup construction period. 

SUMMARY COMMENTS 

The alternative selected for cleanup of the Kesterson Reservoir 
and the San Luis Drain should protect fish and wildlife resources 
from the contaminant conditions which exist at these facilities. 
To provide this protection, it should be clearly demonstrated, 
not hypothesized or speculated, that the action would prevent, 
not merely reduce, further impacts, particularly death and defor- 
mity, to the biota, through all waterborne exposure and food 
chain uptake for all species, across all seasons, and within all 
habitats . 

The Flexible Response Plan-Wet Option and the Immobilization 
Plan-Pond Option phases of the proposed action do not reflect the 
type of assurances that we believe necessary in a proposal to 
eliminate the serious impacts to fish and wildlife resources that 
are continuing to occur at Kesterson Reservoir. 

In light of the unknowns related to current contaminant cleanup 
techniques, we believe that any alternative that would leave con- 
taminated soils, sediments, and vegetation in place in the Kes- 
terson Reservoir and SLD would pose an unacceptable level of risk 
to fish and wildlife resources. The implementation of our "envi- 
ronmentally preferable alternative" would provide for safe future 
management of the Reservoir and associated SLD. We believe that 
the risks of death and deformity to fish and wildlife resources 
can only be eliminated if the contaminated sediments and vegeta- 
tion are removed and disposed offsite in an environmentally 
acceptable manner. Since sufficient scientific data do not exist 
to support the assumption that the subject NWR cells can be safe- 

54 ly flooded, biologically, by water at any depth, we believe that 
the cells should be maintained and monitored in a dry state, 
after removal of contaminated soil and vegetation. Loss of 1,280 
acres of wetland habitat should be fully mitigated. Cleanup, in 
terms of eliminating death and deformity of fish and wildlife 
from contaminants, should be complete by February 1988. 

The FEIS is scheduled for release by October 1986 and must in- 
clude detailed information that will be forthcoming in the Ser- 
vice's Biological Opinion, rendered under formal Section 7 con- 
sultation with the Bureau. The Bureau should take any measures 

55 necessary to ensure completion of the Biological Assessment 

10 

5-17 



55 



56 



report and its delivery to our Sacramento Endangered Species 
Office prior to initiation of formal consultation. The Service 
has 90 days to develop the Biological Opinion after initiation of 
formal consultation by the Bureau pursuant to Section 7 of the 
Endangered Species Act. 

Since interim replacement habitat should be established for on- 
going, current impacts to wildlife resources prior to removal of 
any existing vegetation, we request that the Bureau expeditiously 
develop and implement an interim mitigation plan. 



The Service will continue to work closely with the Bureau in the 
development of an environmentally acceptable solution to the Kes- 
terson Reservoir and SLD cleanup and future land use issue. We 
will continue to provide technical assistance into the develop- 
ment of needed plans and discussions. 

If you have any questions regarding our review comments, please 
do not hesitate contacting me or meeting with Service staff as 
needed. 



Attachments 




5-18 



Attachment 1 . Evaluation of Environmentally Preferable 
Alternative Options for Reservoir Cleanup 

Numerous cleanup techniques on how to reach an acceptable level 
of risk to fish and wildlife resources from continuing contami- 
nant exposure at Kesterson Reservoir have been reviewed. Of the 
six alternative options identified, the Service believes that Op- 
tion F would have the fewest adverse impacts on fish and wildlife 
resources and is therefore considered by the Service to be the 
environmentally preferable alternative. 

Cleanup under all options should be completed by February 1988 

Option A . 

* Offsite disposal of top six inches of soil and vegetation 

* Monitor forcontinued presence of contaminants 

* Rehabilitate cells including firm supply of quality water 

* Same for SLD 

* Use environmentally preferred disposal site (Service 
involved in site selection) 

* Initiate interim mitigation for lost habitat (especially cattails) 
Option B . 

* Offsite disposal of SLD sediments and top six inches of 
"hot spots" areas 

* Surficial removal of remaining soils/vegetation to onsite 
lined/capped site, south of Gun Club Road 

* Restore cells on north side of Gun Club Road 

* Water as in Option A 

* Interim mitigation as in Option A 

* Long term mitigation for replacement habitat for onsite disposal are 
Option C . 

* Remove top six inches of soil and dispose onsite with state- 
of-the-art techniques for containment 

* Leave cells dry; grade to prevent standing water 

* Mitigate for 1,280 acres of wetlands 

1 



5-19 



Clean water to mitigation area 
Monitor animals/plants on former reservoir 
Transfer of disposal (containment) site to the Bureau 
Option D 



Cleanup of Reservoir to meet WQ-85-1 dictates 

Onsite disposal of Reservoir (only) materials via identified 
standards 

Restore best units to baseline habitat value (1972-1978) 
conditions (water supply, control structures, etc.) 

Offsite mitigation - where not restored 

Implement monitoring program 

Cleanup actions to result in no adverse affects to NWR lands 

Transfer & M for onsite disposal site to the Bureau 

Option E . 



Do #D plus R&D element to test logic of wet/dry; on one cell 
Return other cells to baseline 
Mitigate for lost habitat 
Mitigate for interim impacts 

Must provide for monitoring and corrective action, if needed 
Option F . The Selected Environmentally Preferable Alternative 



Immediately implement establishment of replacement habitat 
(to be established prior to removal of existing vegetation) 

Allow all cells to go dry 

Remove vegetation and top six inches of soil (or that amount 
of material required to effectively eliminate contaminated 
soil and vegetation) in all twelve cells of Reservoir and 
dispose offsite 

Mitigate for loss of 1,280 acres of wetland habitat 

Monitor existing plants, animals, and water 

2 

5-20 



Implement corrective actions in an environmentally 
acceptable manner, if contamination persists (e.g., (1) 
fill with clean soil, (2) further removal of soil and 
vegetation, and (3) contain, treat, and/or dispose of 
surface/ground water 



EVALUATION MATRIX 













C 


riteria 








A 




bas 


eiine 


mi 


tigat 


ion 


moni tori 


ng 


risk 


1 






1 




2 




3 




4 


t 




















e 


















r 


A 




+ 




+ 




+ 




M- 


n 


B 




- 




+ 




+ 




M+ 


a 


C 




- 




+ 




+ 




M+ 


t 


D 




+- 




+ 




+ 




M 


i 


E 




+- 




+- 




+ 




H 


V 


F 




- 




+ 




+ 




L 


e 




















s 





















Definitions of Symbols 
Criteria: 



1. Provides for return of habitat values to baseline 
conditions (1972-1978) 

2. Provides for long-term and interim mitigation 

3. Provides for monitoring and corrective action 
4. Provides for little or no risk of contaminant 

exposure to fish & wildlife resources 



Ranking symbols: 



+ meets criteria 

- does not or less than meets criteria 

M medium risk to resources 

H high risk 

L low risk 

M- less than medium 

M+ more than medium 



5-21 



Attachment 2 . - Interim Mitigation Proposal - Kes terson 
Reservoir Cleanup 

The following wetland rehabilitation projects, with their 
respective materials lists, have been prioritized . 

A. BIG LAKE/SALT SLOUGH INLET - Project completion would allow 
Salt Slough/San Joaquin River flood flows to enter Big Lake, yet 
remain within the Big Lake basin following termination of flood 
flows, plus allow water management during normal operations. 
Specific work would entail the repair of the eroded and washed out 
levee, placement of water control structures for management 
purposes, plus levee rip-rap placement. Estimated marsh acreage 
affected beneficially: 80. 



Estimated Materials: 

1. Corrugated Metal Pipe (cmp) - 80' (two 40' pipes consisting 
of20' sec t ions ) of 48" diameter round. Appropriate connecting 
bands ( not dimple-type). 

2. Flap gate - one 48" diameter. 

3. Screw/flap gate - one 48" diameter on 5' stub with a 7' frame 
height . 

4. Filter blanket (fiberglass) for levee protection. 8"-10" 
angular rip-rap. Both sides of levee. 

5. Should on-site soils prove unacceptable, imported material 
for levee repairs and fill material for cmp installation would be 
necessary . 

B. WINDMILL POND/BIG LAKE DIKE REPAIR - Project completion would 
allow the impoundment and management of water discharge from the 
Windmill Pond Complex to Big Lake. Specific work would entail the 
rehabilitation of an existing levee, the installation of a 
corrugated metal pipe and water control structure plus associated 
levee rip-rap. Estimated marsh acreage affected beneficially: 
25. 



Estimated Materials: 

1. Corrugated metal pipe - 40' (two 20' sections) of 36" 
diameter round. Appropriate connecting bands. 

2. One vertical, half-moon riser, 8' high x 48" wide, with 
lO'cmp stub, 36" diameter. 



5-22 



3. One water spreader for discharge end of cmp. 

4. Filter blanket and 8"-10" rip-rap (angular) facing on both 
sides of levee. 

5. Access ramp to control structure. 

C- WINDMILL POND DRAIN TO MUD SLOUGH - Project would allow 
complete drainage of the main Windmill Pond unit, thus giving 
managers the opportunity to perform moist-soil management 
practices. The complete drainage at this point would alleviate 
salt buildups via periodic flushing of the unit plus assist in 
disease outbreaks which have periodically occurred in the 
heretofore, undrainable portion of the unit. Estimated marsh 
acreage affected beneficially: 25. 

Estimated Materials: 

1. Corrugated metal pipe - 40' (two 20' sections) of 30" 
diameter round. Appropriate connecting bands. 

2. One vertical, half-moon riser - 7' high, 42" wide with 10' 
cmp stub, 30" diameter. 

3. One water spreader for discharge end of pipe. 

4. Rip-rap (8"-10" angular) facing on both sides of levee. 

5. Access ramp to control structure. 

D. ROAD CR OSS ING - SAN LUIS DRAIN ROAD TO WINDMILL POND - 
Project c o m p 1 e t i on w ou 1 d allow all-weather access to 
aforementioned projects. Road crossing currently is inaccessible 
to vehicular traffic during heavy rains and associated flood 
waters . 

Estimated Materials: 

1. Corrugated metal pipe - 30 ' x 36" diameter round. 

2. One water spreader for discharge end of cmp. 

3. Appropriate fill dirt for approximately 150' of road bed. 

4. Appropriate road gravel, 4-6" deep, 10' top. 

5. Rip-rap (8"-10" angular) facing on both sides of pipe 
installation. 



5-23 



The completion of the four projects, plus the provision 
of an acceptable water supply and distribution system, would 
allow managers to create and intensively manage wetland habitat 
on the eastern half of the Kesterson National Wildlife Refuge. 
This habitat would partially provide alternate habitat for 
species displaced by the multi-year clean-up operation at the 
Kesterson Reservoir. A variety of waterfowl species, marsh 
birds, tri-colored blackbirds, northern harriers, plus 

mammalian predators associated with wetlands and their 
inhabitants, would benefit from these projects. Improved wetland 
habitat at Big Lake and the mile-long, natural channel between 
the Windmill Pond and Big Lake would also provide improved public 
waterfowl hunting conditions, thus mitigating to a degree loss of 
hunting opportunity over the last 3 years at the Kesterson 
Reservoir . 



Construction should be completed by October 1, 1986, thus 
allowing refuge personnel the opportunity to apply good quality 
water via the San Luis Canal during the Grassland Water 
District's fall flood-up of the North Grassland marshlands. 
Because of our extensive experience in the water control 
structure installation business (exclusively for marsh 
management), we stand ready to show Bureau personnel successful 
examples of similar installations. If requested, a technical 
advisor from the refuge operations staff would be available dur- 
ing the field construction. 



5-24 



58 



Detailed Specific Com m ents for Inclusion into the "Errata " 
Section of the PEIS 

Page viii. The Immobilization Plan is based largely on specula- 
tion that selenium in the sediments and remaining vegetative 
material would not be available to aquatic birds. Those species 
57 feed extensively on aquatic invertebrates (e.g., raidge larvae, 
damselfly and dragonfly nymphs, etc.) that live in and among 
bottom materials, where they may accumulate selenium under this 
alternative and the Flexible Response Plan, wet option. 

Page xxiv, first paragraph. Vegetation and Wildlife. The Flexi- 
ble Response and Immobilization Plans may reduce risks ... (or 
would theoretically reduce ...). The high degree of uncertainty 
concerning the likelihood of success is clarified in the follow- 
ing paragraph of the DEIS and on pages 4F-23,24, and 25; 4K- 
27,28,29,30,31,32, and 39. The lead sentence in this paragraph 
should reflect this uncertainty. 

Page 1-2. The second sentence of the last paragraph on this page 
59 should state that "Mortality and deformity of aquatic bird 
embryos and chicks was observed at Kesterson Reservoir ..." 

Page 1-3, end of first paragraph. ...as well as SLD sediments 
were contaminated. Here and elsewhere throughout the DEIS (e.g., 
pages 4G-1,2, and 3, 4H-12, etc. the reference to Saiki 1985 
should be updated to Saiki 1986, and the References (page 9-12) 
should reflect that the paper was published in 1986 (pages 67-76 
in the Proceedings volume). 

Page 3-10. The following references should be cited at appro- 
priate spots within the first paragraph: Ohlendorf et al. in 
press a,b; Ohlendorf 1985; Ohlendorf pers. comm. 1985a, b; Clark 
pers. comm. 

Page 3-10. Similarly, appropriate reference citations should be 
added in the second paragraph. 

I Page 3-18, last paragraph of "Vegetation". How long is "after a 
certain number of years"? 



60 



61 



63 



Page 3-24, second-to-last paragraph. It seems important to "know 
how important other transport mechanisms are". 



Page 3-25, first two paragraphs. In further exploration of this 
alternative, effects on animals that eat cattails (e.g., musk- 
rats) should be considered. Pages 4F-10 and 11 and 4F-21 state 
that cattails and other marsh plants are likely to oxidize sel- 
64 enium, although the degree of mobilization is not known. Duck- 
weed is likely to blow to one side of the ponds on windy days 
(Page 4F-25), thereby not effectively blocking light penetration 
to the pond bottoms. 

1 

5-25 



Page 3-25. The top paragraph states that cattails may extract 
some selenium. We suggest the word "may" be changed to "will" as 
cattails are known to take up selenium in their roots. The immo- 
bilization plan is unlikely to change this condition. Wind drift 
and wildlife probing in the pond bottoms will also contribute to 
sediment disturbance making it difficult for sediment immobiliza- 
tion. 

Page 3-26, third paragraph. The harvested material that "would 
be left in place" would very likely drift to the downwind sides 
of the ponds, once they are flooded (see page 4F-25 Pond Option). 
It seems unlikely that selenium in this vegetative material would 
be effectively immobilized. The degree of immobilization and un- 
availability to invertebrates remains speculative. 

Page 3-30. Under Wetland Mitigation, the DEIS indicates "Pur- 
chase up to 118 gross acres..." An explanation of the 118 acres 
should be made in the text. Page 13-31, fourth paragraph 
indicates 64 acres. 

Page 3-33. The top paragraph discusses drying out of sediments. 
We recommend that the location of the drying area be indicated. 

Page 3-57, Offsite Disposal Plan. This plan to use Reverse Osmo- 
sis (RO) treatment appears questionable as RO treatment on a 
large scale has not been proven and may take years to perfect. 

Page 4A-4, last paragraph before "Concentrations of Selenium." 
The potential boron problem for wildlife should be mentioned 
briefly here (see the last paragraph before "Bioaccumulation of 
Contaminants," page 4H-15). 

Page 4A-10. Some of the selenium also occurs in animals (as 
shown in Figures 4-7 and 4-21), or has been "exported" by them as 
they left Kesterson Reservoir. 

Page 4A-20. Impacts of Offsite Mitigation Actions. If the Galio 
property is to be developed for wetland mitigation, it is likely 
that the removal of 6 inches of topsoil throughout the site would 
be detrimental to the site improvements planned for mitigation. 
An alternative site for site cap material at Kesterson Reservoir 
is recommended. 

Page 4E-5, paragraph 5. The statement is made that beneficial 
uses are not inhibited in waters surrounding Kesterson or the 
SLD. The State Health Department and Department of Fish and Game 
have warned people not to eat excess amounts of fish and water- 
fowl from these waters. This suggests that beneficial uses are 
inhibited. 



5-26 



71 



73 



76 



77 



Page 4F-7. The second paragraph states that Westlands Water 
District cleared all vegetation from the RO site and prepared a 
mitigated Negative Declaration on the action. The site included 
a wetland. It should be stated that the wetland loss of 5 acres 
plus was never mitigated. 



Page 4F-10, second paragraph. The paper by Wilson and Tchobana- 
glous is now published, with 1986 date. Update is needed 
72 wherever it was mentioned (e.g., pages 4F-12 and 24), and in the 
References . 

Page 4F-14, lines 3-8. At the Volta Wildlife Area, an uncontami- 
nated wetland near Kesterson NWR, Saiki (1986) found an average 
of 0.495 ppm selenium dry weight (range = undetectable to 0.79 
ppm) in 10 samples of submerged aquatic plants, including sago 
pondweed (Potamoge_ton Eectinajtus) , water milfoil (M yriophyllu m 
sp.) and an unidentified plant (probably bur reed, Sparganium 
sp. ) . 

Page 4F-14, lines 18-20. In 33 samples of submerged plants (wi- 
geon grass and horned pondweed) collected from Kesterson Res- 

74 ervoir and the San Luis Drain in 1983, Saiki (1986) found an 
average of 73 ppm selenium dry weight (range = 18-390 ppm). 

I Page 4F-15, last paragraph before "Boron". ...concentrations in 

75 I vegetation are much higher... 



Page 4F-25, first paragraph - We do not believe floating plants 
would provide complete shading of the pond bottom. 

Page 4F-25, Pond Option - In addition to releases of methylsel- 
enides, selenium from the vegetation would very likely be accumu- 
lated and cycled by aquatic organisms, particularly invertebrates 
that could be eaten by birds. 



Page 4G-1, lines 7-13. Fishes occurring in Mud Slough include 
at least 15 resident warmwater species--goldf ish , Carassi.us 
auratus; common carp, Cyprinus carpio ; threadfin shad, Doroso ma 
E^t^£ll£lis^; mosqui tof ish, Gambusi_a a f f. i.n_i s ; white catfish, 
i£laliii:iis catus; black bullhead, I_^ melas; channel catfish, I_^ 
78 punctatus; hitch, Lavinia exi 1 ica uda ; green sun fish, Lepomis 
cyanellus ; bluegill, L^ m acrochirus ; inland silverside, M enidia 
k^rYll,i,na; largemouth bass, Micro£terus salmonides; red 
shiner , No_tro2As Ayl.ll^lisi.£' Sacramento blackfish, Or_thodon 
microlepidotus ; and fathead minnow, Pim ephales pro m elas — and two 
anadromous species — striped bass, M orone saxatilis ; and chinook 
salmon, Oncorhynchus tsha w ytscha (Saiki, unpubl, data). These 
other species also occur in Salt Slough and the lower San Joaquin 
River (Saiki 1984). 



5-27 



Page 4G-2, lines 2-6. Studies by Saiki (1986) indicated that 
selenium concentrations in fish collected from Salt Slough in 
1984 ranged from 0.62 to 1,5 ppm wet weight. Selenium concen- 
trations in fish collected from Mud Slough in 1984 ranged from 
1.3 to 5.5 ppm wet weight (Saiki 1986). 

Page 4G-2, lines 7-10. Fish samples from the San Joaquin River 
near Hills Ferry Road contained 0.18-1.4 ppm selenium wet weight, 
and fish collected from Suisun Bay contained 0.29-0.51 ppm sel- 
enium wet weight (Saiki 1986). 

Page 4G-2, lines 28-33. The references need to be identified. 

Page 4G-2, lines 40-41 and page 4G-3, line 1. Samples from all 
areas were analyzed for arsenic, cadmium, chromium, copper, mer- 
cury, nickel, lead, selenium, and zinc, whereas only samples from 
the Reservoir and SLD were analyzed for 23 organochlorine 
residues (Saiki 1986). 

Page 4G-2-3. The EIS does not provide a complete listing of Mike 
Saiki's fish data from our September samples done in 1985, 1984, 
and 1983. This should be provided and discussed in fuller 
detail . 

Page 4G-3, lines 5-6. Concentrations of other elements were 
similar in fish from the two sites. Only 2 organochlorine 
residues--p,p'-DDE and Aroclor 1254 — were detected in fish from 
the Reservoir and the SLD, and both residues were at low con- 
centrations (0.06 ppm wet weight). 

Page 4G-3, lines 6-8. The references need to be identified. 

Page 4G-3, lines 10-13. As late as Summer 1983, the SLD north 
of Bass Avenue contained a variety of warmwater fishes such as 
channel catfish , common carp, goldfish, green sunfish, hitch, 
inland silverside, mosqui tof ish, and Sacramento blackfish (Saiki 
1986 and unpubl. data). Since a fish kill in September 1963, 
however, only raosquitofish have been observed in this portion of 
the drain (Saiki 1986). 

Page 4G-3, lines 22-27. South of Manning Avenue, rainfall, 
groundwater seepage, and occasional discharges of irrigation 
water and tailwater constitute the water supply in the SLD, and 
the following fish species occur: common carp, goldfish, black 
crappie (Pom oxis niqro m aculatus ) , threadfin shad, green sunfish, 
Sacramento blackfish, bluegill, and mosquitofish (Saiki, personal 
communication) . 



84 



Page 

Zahm. 



4H-5. Herons are nesting at Sprig Lake this year, per Gary 



85 



Page 4H-7, second paragraph of "Postcontamination". Change the 
reference of "all bird species" to "most bird species. 

4 



5-28 



Page 4H-8. Numbers of shorebirds, etc. are probably an under- 
estimate, based on the number of nests found there during spring 
1985 (see also page 4H-9). 



Page 4H-11, last paragraph, first sentence, 
ring to "endangered and candidate species' 
"federally listed and candidate species." 



Instead of refer- 
please refer to 



Page 4H-12, "State-Designated Species". The peregrine falcon is 
a State designated species. This should be indicated in the 
final EIS. 

Page 4H-12, lines 45-47. Mosquitofish captured at Kesterson 
Reservoir in May 1982 were found to have extremely high levels of 
selenium (Saiki 1986). 

Page 4H-15, lines 40-44. In addition, Saiki (personal communi- 
cation) reported the following preliminary results for inverte- 
brates collected in August 1983 from the SLD: a mean of 160 ppm 
selenium dry weight for damselfly nymphs and 284 ppm selenium dry 
weight for midge larvae. 

Page 4H-17, first paragraph of "Birds". Livers of only two 
ducks were analyzed for Ohlendorf et al., in press a. It would 
be preferable to use a mean of 19.9 ppm for ducks and cite Pres- 
ser, T.S. and K.M. Ohlendorf, Biogeochemical cycling of selenium 
in the San Joaquin Valley of California (in prep.) as the 
reference . 

Page 4H-17, next paragraph. Observations at Volta Wildlife Area 
were in 1983-1985. Killdeer and pied-billed grebes should be 
added to the list of species. 

Page 4H-19. Reference to Ohlendorf pers. comm. b should be 
added at the end of the second paragraph (in reference to coots 
in 1984 and 1985) . 

Page 4H-19, last paragraph before "Mammals." The first sentence 
is awkward. We suggest a rewrite: Little information is 
available in the literature concerning the effects of dietary 
selenium on wild birds. 



Page 4K-21. The correct 
son pond 5 is 4.17 ppm. 



m 



ean value for house mice from Kester- 



Page 4H-22, fourth paragraph. We recommend that ppb values be 
converted to ppm (i.e. 1.4 and 3.0 ppm) for consistency with 
other parts of the text. 

Page 4H-25, No-Action Alternative, second paragraph. Change to 
indicate that migratory waterfowl WILL be attracted to the 450 
acres of seasonal ponds. 



5-29 



Page 4H-36, top paragraph refers to safe selenium levels in 
92 I wildlife. See comments under page 4G-7. 



93 



94 



Page 4H-39 under Brine Ponds. This paragraph should indicate 
that hazing would be necessary during all periods of the year 
(not just during the nesting period). 

Additions and corrections to the Literature Cited chapter are as 
follows : 

Page 9-12, lines 34-36. Saiki, M. K. 1984. Environmental 
conditions and fish faunas in low elevation rivers on the 
irrigated San Joaquin Valley floor, California. Calif. 
Fish Game 70( 3) : 145-157. 

1986. A field example of selenium contamination in 
an aquatic food chain. First annual environmental symposium; 
selenium in the environment; proceedings. Calif. Agric. 
Tech. Inst., Publ. No. CATl/860201, pp. 67-76. 

Page 9-12, lines 37-42. (Omit these 2 references?) 

Page 9-12. "Saiki, M.K. 1986" was published in 1986 (pages 
67-76 of the proceedings). The symposium dates were June 
10-12, 1986 (not 1983) . 

Page 9-20. Corrections are needed for both Ohlendorf 
personal communications: a) the field station is in Davis, 
not Dixon; b) the memorandum was dated February 20, 1986 and 
addressed to FWS Drainwater Studies Coordinator (not to Dr. 
Trauger). (This personal communication (b) could be handled 
the same way as the other memo to Steve Moore (dated April 
26, 1985) that is listed in References on page 9-11. 



5-30 „ 

I 



Response to Comments of the U. S. Fish and Wildlife S ervice 

1. The USFWS review comments were received and incorporated 
into the Draft EIS by the USER. 

2. The USFWS' environmentally preferred alternative is dis- 
cussed in the Summary section of this Final EIS, and will 
also be discussed in the Kesterson Program Record of 
Decision, which is scheduled for December 1, 1986. 

3. The USER appreciates the continuing input and cooperation 
of the USFWS. 

4. The USER Eiological Assessment, which includes a well- 
defined proposed action, was transmitted to USFV/i^: in mid- 
August. It was not possible to append the USFWS Biological 
Opinion to the Final EIS and still maintain the Final EIS 
schedule. The Biological Opinion however, will be made 
part of the Secretary's Record of Decision on the Kesterson 
Program. 

5. The user's interpretation of WQ 85-1 is that February 1988 
represents the date by which implementation of a Kesterson 
Reservoir cleanup plan must be initiated, and not the date 
by which cleanup must be completed. The USER intends to 
initiate implementation of the FRP in March 1987. The 
nuisance abatement component of this plan includes a number 
of measures to be taken to reduce risks of wildlife con- 
tamination during the initial 5-year period of the plan; 
see the proposed action description contained in this Final 
EIS. 

6. Please see the discussion of FRP risks in Chapter 3 of this 
Final EIS. 

7. Please see the discussion of FRP risks in Chapter 3 of this 
Final EIS. 

8. Please see the discussion of FRP risks in Chapter 3 of i-his 
Final EIS. 

9. The Draft EIS description and analysis of the Kesterson 
Reservoir biota and associated chemical/physical conditions 
across time and habitats were intended for a general audi- 
ence. The USER continues to feel that this discussion is 
adequate. It was based upon the best information available 
from the USFWS, as well as published and unpublished liter- 
ature. Many of the recent USFWS studies on the extent of 
vertebrate contamination at Kesterson Reservoir were un- 
available for citation because they had not undergone 
internal review. Relatively few studies, including those 
conducted by the USFWS, have addressed the extent of 



5-31 



contamination of the ma]or food chain elements at Kesterson 
Reservoir including: plankton, epiflora, emergent and 
submergent vascular plants, or invertebrates (epifauna, 
free-swimming invertebrates, or benthic invertebrates). 
Studies of many of these organisms are currently being 
conducted by UCB/LBL, and they will be a major focus of the 
monitoring program which is being conducted under the FRP . 
This monitoring program will consider spatial and temporal 
variance in contaminant levels for selected indicator taxa 
in all the major habitat types at Kesterson Reservoir. It 
will also analyze the importance of detrital pathways for 
selenium cycling and biological mobilization. 

10. The USBR appreciates this comment, but considers it very 
unlikely that waterfowl and other wildlife are making 
"direct use of sediments at Kesterson Reservoir." Instead, 
these birds are foraging for adult and larval insects 
(e.g., damselflies, dragonflies, and soldier flies) that 
live in the sediments. These food chain organisms will be 
examined in the proposed monitoring program described in 
the Final EIS. 

11. Please see the discussion of FRP risks in Chapter 3 of this 
Final EIS. 

12. The Draft EIS (p. 4F-25) recognizes that it may be possible 
to maintain an extensive and relatively uniform growth of 
Nitella in the ponds. The use of Nitella in deep ponds to 
assist in selenium immobilization will be tested in moni- 
toring of Pond 4 as part of the FRP. 

13. Please see the discussion of FRP risks in Chapter 3 of this 
Final EIS. 

14. Please see the discussion of FRP risks in Chapter 3 of this 
Final EIS. 

15. Please see the discussion of FRP risks in Chapter 3 of this 

Final EIS. 

16. Please see the discussion of FRP risks in Chapter 3 of this 
Final EIS. 

17. Please see the discussion of FRP risks in Chapter 3 of this 
Final EIS. 

18. Please see the discussion of FRP risks in Chapter 3 of this 
Final EIS. 

19. Please see the discussion of FRP risks in Chapter 3 of this 
Final EIS. 

20. Please see the discussion of FRP risks in Chapter 3 of this 
Final EIS. 



5-32 



21. The acceptable/unacceptable levels of selenium in water and 
biota at Kesterson Reservoir are currently under study by 
the USER and the USFWS . Current goals at Kesterson Reser- 
voir are 3 mg/kg for waterfowl and mammal food chain ele- 
ments, and 5 mg/kg for fish food chain elements. These 
values will be refined for individual taxa as more data 
become available from ongoing studies by the USFWS, LBL, 
and others. 

22. The nuisance abatement program included in USBR's proposed 
action is designed to minimize contamination of wildlife 
during the initial 5 years of FRP implementation. Follow- 
ing that time, either the FRP will have been shown (through 
monitoring) to be safe for wildlife, or an alternative plan 
providing such safety will be implemented. Possible miti- 
gation for lost wetland habitat values at Kesterson Reser- 
voir is discussed in the proposed action description 
contained in this Final EIS. 

23. The cost of implementing all three alternatives would be 
greater than implementing a single action. The USER 
believes, however, that the phased approach is a respon- 
sible method for achieving cleanup of Kesterson Reservoir 
because of the possible cost savings and the opportunity to 
use the latest available data in selecting cleanup 
alternatives . 

24. These topics are discussed in the proposed action descrip- 
tion contained in this Final EIS. 

25. A biological monitoring program is included in the proposed 
action description contained in this Final EIS. It incor- 
porates USFWS suggestions regarding indicator species and 
threshold levels. 

26. The ultimate state of Kesterson Reservoir is described in 
the Land Use sections of the proposed action description 
contained in this Final EIS. 

27. No physical cleanup of the SLD is proposed at this time. 
Water will be added to the SLD to maintain the structure 
and to keep the accumulated sediments covered. The Final 
EIS proposed action description more fully describes the 
proposed management of the SLD. 

28. The Final EIS more fully describes the proposed action and 
clarifies the relationship between these options. For 
example, water levels will be higher under the Immobili- 
zation Plan than they will be under the FRP. 

29. The Final EIS contains information about water depths and 
water quality for the proposed action. 



5-33 



30. Under the FRP , water from the DMC will not be used to fill 
the wet ponds. Rather, the water supply will be derived by 
pumping groundwater beneath Kesterson Reservoir. 

31. The Final EIS proposed action description specifies the 
treatment of each pond under each phase of the proposed 
action. 

32. The USFWS must assess the compatibility of the project area 
to management of Kesterson NWR. The USFWS has indicated 
that it will make this assessment prior to the Record of 
Decision on the Kesterson Program, which is scheduled for 
December 1, 1986. The USER will coordinate with USFWS on 
this issue. 

33. The onsite landfill will be designed to meet the require- 
ments of Title 23, California Administrative Code, Subchap- 
ter 15. Preliminary design is contained in the Final EIS 
description of the proposed action. 

34. The USER appreciates USFWS ' s independent development and 
evaluation of alternative cleanup approaches for Kesterson 
Reservoir. USFWS' environmentally preferred alternative is 
recognized in the Summary section of this Final EIS. 

35. The USER appreciates the USFWS recommendation of a pre- 
ferred alternative for SLD treatment. Please see the 
discussion of FRP risks in Chapter 3 of this Final EIS. 

36. The USER is presently improving wetland habitat on the east 
side of Kesterson NWR to assist in hazing and nuisance 
abatement . 

37. USFWS' environmentally preferred alternative is recognized 
in the Summary section of this Final EIS. 

38. USFWS' environmentally preferred alternative is recognized 
in the Summary section of this Final EIS. 

39. The Final EIS (Chapter 2) more fully describes wetland 
mitigation associated with the USSR's proposed action, and 
recognizes USFWS' recommendation. 

40. The Final EIS more fully describes the USER'S proposed 
action, which includes an extensive monitoring program 
under all alternatives. 

41. The Final EIS describes the decision criteria and correc- 
tive actions which are part of the USER'S proposed action. 
Specific corrective measures include those suggested by the 
USFWS in this comment. 

42. The alternative of otfsite disposal was considered in the 
Draft EIS, and rejected for reasons stated on p. 3-41 of 



5-34 



the Draft EIS. Existing Class II landfills have a number 
of problems, such as lack of sufficient capacity, regula- 
tory problems, and/or public controversy. Should excava- 
tion of sediments and soils be necessary, USER is designing 
an onsite disposal facility which minimizes risks of wild- 
life contamination. 

43. The onsite landfill is being designed to meet the require- 
ments of Title 23, California Administrative Code, Sub- 
chapter 15. As part of the CPMP submitted to the SWRCB, a 
monitoring and contingency plan will be developed. The 
contingency plan will describe action to be taken in the 
event of failure. 

44. In response to this comment, USER has modified the Onsite 
Disposal Plan by eliminating flooding of the cells follow- 
ing excavation. 

45. USFWS ' mitigation recommendations are recognized in Chap- 
ter 2 of the Final EIS. 

46. USER is presently improving wetland habitat on the east 
side of Kesterson NWR to assist in hazing and nuisance 
abatement activities. 

47. Mitigation alternatives are discussed in the proposed 
action description contained in this Final EIS. USFWS' 
mitigation recommendations are recognized in this discus- 
sion . 

48. Please see the response to conunent 47. 

49. The USER acknowledges the USFWS position. 

50. Costs of mitigation alternatives are currently being 
refined in consultation with USFWS. 

51. The Eiological Assessment describes potential conservation 
measures for candidate and endangered species (see 
Chapter 1 of the Final EIS). The USER will review USFWS 's 
Eiological Opinion recommendations before making final 
decisions on conservation measure selection, design, and 
cost. These final decisions will be reflected in the 
Kesterson Program Record of Decision. 

52. The USER is presently improving wetland habitat on the east 
side of Kesterson NWR to assist in hazing and nuisance 
abatement activities . 

53. Please see the discussion of FRP risks in Chapter 3 of this 
Final EIS. 

54. USFWS' environmentally preferred alternative is recognized 
in the Summary section of this Final EIS. 



5-35 



55. The Biological Assessment was delivered to USFWS on 
August 15, 1986. 

56. Please see the response to conunent 52. 

57. Please see the discussion of FRP risks in Chapter 3 of this 
Final EIS. 

58. Please see the discussion of FRP risks in Chapter 3 of this 
Final EIS. 

59. The suggested clarification is editorial in nature and does 
not change the essential conclusions of the Draft EIS 
regarding impacts of the alternatives. P. 1-2 contains a 
short summary regarding findings of contamination at 
Kesterson Reservoir. The fact that mortality and deform- 
ities of aquatic bird embryos and chicks were observed in 
1983 is specifically stated in the detailed description of 
the extent of wildlife contamination found at p. 4H-14. 

60. This reference (Saiki 1986) was in draft form when the 
Draft EIS was prepared. The errata sheet indicates the 
corrected citation. 

61. The USER appreciates the references to the research of Drs . 
Ohlendorf and Clark. In Chapter 3 of the Draft EIS, how- 
ever, the discussion of the extent of wildlife contamina- 
tion at Kesterson Reservoir is intended to be a brief 
summary of this problem. A more detailed discussion of 
wildlife contamination, including all of these references 
and many others, can be found in Chapter 4, Section H, 
p. 12-22. The reader will note that none of the discus- 
sions in Chapter 3 — soils and sediments, groundwater, 
surface water, vegetation, and air--cite references. The 
purpose of these discussions is to summarize major con- 
cerns, rather than to provide detailed analysis. 

62. The duration of FRP biological monitoring is described in 
the Final EIS proposed action description. 

63. Please see the discussion of FRP risks in Chapter 3 of this 
Final EIS. 

64. Pp. 3-25 to 3-26 of the Draft EIS describe the Immobiliza- 
tion Plan in general terms. These comments concern impacts 
of this plan, impacts which are described in Chapter 4 of 
the Draft EIS. For example, muskrats using cattails as 
food are mentioned on p. 4H-25 of the Draft EIS. 

65. Although the landfill acreage as estimated on p. 3-31 of 
the Draft EIS is approximately 64 acres, up to 118 acres of 
oftsite mitigation wetland (as noted on p. 3-30) was in- 
cluded in the Draft EIS Wetland Restoration/Onsite Disposal 
Plan to provide flexibility and a buffer area. As 



5-36 



described in the Final EIS, the landfill has been relocated 
to Pond 3 and reduced in size to about 30 acres, plus a 
10-acre buffer area. 

66. Excavation and drying of SLD sediments are not part of the 
proposed action. 

67. The USER agrees that although reverse osmosis has been 
proven on a large scale, it would be very expensive. This 
was one of the reasons for not selecting reverse osmosis 
for treatment of extracted groundwater as part of the 
proposed action. 

68. The USER shares the USFWS concern regarding impacts of con- 
taminants to wildlife. Chapter 4, Section A, addresses 
Topography, Geology, and Soils. Impacts to wildlife from 
boron and selenium are addressed, as noted by the 
commenter, in Chapter 4, Section H. 

69. The USER agrees with this observation. As noted on 
p. 4A-21 of the Draft EIS, removal of topsoil from the 
Gallo property would reduce productivity of residual soils 
for aquatic vegetation. Alternative sites for a site cap 
under the Immobilization Plan are not, however, currently 
being pursued because the site cap option is not included 
in the USER'S proposed action. 

70. The USER agrees with this comment. The errata sheet indi- 
cates the suggested change. 

71. The Westlands Water District action is not part of the 
USER'S Kesterson Program. Mitigation alternatives for USER 
actions are contained in the Final EIS description of the 
proposed action. 

72. Wilson and Tchobanoglous ' s (1985) unpublished paper has 
been published since release of the Draft EIS (Wilson and 
Tchobanoglous 1986) . Results of the impact analysis are 
not affected. 

73. The finalized version of Saiki's (1986) paper clarifies the 
information cited here. Results of the impact analysis are 
not affected. The errata sheet reflects clarifications 
resulting from Saiki's (1986) paper. 

74. The finalized version of Saiki's (1986) paper clarifies the 
information cited here. Results of the impact analysis are 
not affected. The errata sheet reflects clarification 
resulting from Saiki's (1986) paper. 

75. The language referenced is the result of a typographical 
error. The errata sheet reflects the intended language. 



5-37 



76. Please see the discussion of FRP risks in Chapter 3 of this 
Final EIS. 

77. Please see the discussion of FRP risks in Chapter 3 of this 
Final EIS. 

78. The list of fish species occurring in Mud Slough provided 
on p. 4G-1 of the Draft EIS was intended to be illustrative 
rather than exhaustive. The USER appreciates the list of 
additional resident warmwater and anadromous fishes, and 
recognizes that the other species mentioned also occur in 
Salt Slough and in the San Joaquin River. The existence of 
these additional fish species does not change any major 
conclusions reached in the Draft EIS. 

79. The USER appreciates this USFWS input. The errata sheet 
indicates the suggested change. 

80. The USER believes that the summary comparisons of selenium 
concentrations of mosquitofish from Kesterson Reservoir and 
the Volta Wildlife Area provided in the Draft EIS 
(pp. 4G-2,3) are adequate to indicate the major trends. 

Those desiring more detail on this subject should refer 
directly to Saiki (1986) . 

81. The USER appreciates this USFWS input. The errata sheet 
indicates the suggested changes. 

82. The Draft EIS (p. 4G-3, lines 10-13) states that "Before 
1983, the SLD supported a warmwater fishery similar to that 
described for Kesterson Reservoir. Since 1983, however, 
only mosquitofish have been observed in this portion (north 
of Bass Avenue) of the drain." The USER believes that this 
continues to be an accurate statement, and appreciates this 
additional list of warmwater fishes that occurred in this 
portion of the SLD prior to 1983. 

83. The Draft EIS (p. 4G-3, lines 22-27) indicates that rain- 
fall and groundwater seepage constitute the main water 
supply in the SLD. Occasional discharges of irrigation 
water and tailwater should also be included in the SLD 
water supplies since 1983. The Draft EIS also indicates 
that other fish species in addition to those mentioned may 
occur in the SLD south of Manning Avenue. The USER appre- 
ciates the additional list of fish species from this reach 
of the SLD. 

84. The nesting status of black-crowned night-herons at Sprig 
Lake was unknown when the Draft EIS was prepared. This 
information is reflected in the errata sheet. This change 
in nesting status does not alter any conclusions reached in 
the Draft EIS because Sprig Lake is outside the project 
area . 



5-38 



85. The USER agrees with the suggested change. The errata 
sheet indicates the revision. 

86. The number of shorebirds , grebes, herons, etc. indicated in 
Table 4-40 (pp. 4H-8 and 9) of the Draft EIS were taken 
from USFWS unpublished data in the San Luis NWR files. The 
USER is not aware of any additional USFWS data that will 
change these estimates of the numbers of waterbirds using 
Kesterson Reservoir since the initiation of the hazing 
program. An increase in shorebird numbers during this 
period, however, should not change any major conclusions 
reached in the Draft EIS. 

87. The USER agrees with the suggested changes. The errata 
sheet indicates the revisions. 

88. The suggested change is editorial in nature and does not 
alter the conclusions of the Draft EIS. The USER and its 
consultants attempted to write the Draft EIS in a clear, 
concise fashion. It is recognized that other editorial ap- 
proaches could have also accomplished these goals. 

89. The errata sheet indicates the suggested change. 

90. The values given in the Draft EIS are correct, but the USER 
agrees that consistent use of units is appropriate. The 
errata sheet indicates the suggested change. 

91. The errata sheet indicates the suggested change. 

92. This comment is unclear, as no comments are given under 
p. 4G-7. Communication with the USFWS indicated that the 
comment was intended to reflect concern over safe selenium 
standards in water to protect wildlife, discussed on page 
4H-36. The top paragraph on p. 4H-36 refers to safe selen- 
ium standards for wildlife. A 5 pg/1 standard is currently 
considered by USER to be a "safe" standard for wildlife; 
this value may be revised when the results of ongoing USFWS 
studies are available. USFWS recommends a standard of 
2 yg/l. Please see the discussion of this issue in 
Chapter 3 of the Final EIS. 

93. USFWS concerns regarding hazing are noted. The use of a 
reverse osmosis plant and brine pond were discussed under 
the Offsite Disposal Plan in the Draft EIS, but these 
facilities are no longer under consideration under the 
proposed action. 

94. The errata sheet indicates the suggested changes. 



5-39 




United States Department of the Interior 



In Reply Refer To; 
WGS-Mail Stop 423 
DES 86/21 



GEOLOGICAL SURVEY 
RESTON. VA 22092 



July 9, 1986 



Memorandum 

To: Director, Office of Environmental Affairs, Bureau of Reclamation 



From: 



Assistant Director for Engineering Geology 



Subject: Review of Draft Environmental Statement - Kesterson Program, 
Merc-ed and Fresno Counties, California 

We have reviewed the statement as requested in your memorandum dated 
April 30 to the Director, U.S. Geological Survey. Our comments of a 
general nature relating to the structure and overall findings of the 
Statement are presented below while our specific technical comments are 
provided in the attachment. 

The Draft Statement contains much useful information but the organization 
of the document by resource topics results in a high degree of repetition, 
requires extensive cross referencing between sections and suggests a frag- 
mented assessment of impacts. We found it rather difficult to determine the 
overall impacts and identify deficiencies or benefits of the proposed alter- 
natives for cleanup of Kesterson Reservoir and the San Luis Drain (SLD). 
Consideration should be given to organizing the Final Statement by alter- 
native cleanup options with a discussion of resource topics within each 
alternative. This would, in our view, provide a means for readily assessing 
the impacts and benefits of each alternative considered. 



Bioaccumulation and food-web transfer are princ 
with the wildlife toxicity observed at Kesterso 
statement provides only a simplistic presentati 
more, none of the proposed alternative plans co 
of the effects on these food webs. The complex 
biological systems involving changes in communi 
function on short-term (days to months) and Ion 
be introduced early in the statement. This wou 
reader to evaluate and interpret other informat 
selenium in water and sediment with an understa 
wildlife toxicity. 



ipal mechanisms 
n Reservoir and 
on of food webs 
ntain a realist 
and dynamic na 
ty composition, 
g-term (years) 
Id provide the 
ion such as con 
nding of its re 



associated 
the SLD. The 
and further- 
ic analysis 
ture of 
abundance and 
periods should 
basis for the 
centrations of 
lation to 



Flow-rate data and reservoir volumes are not provided for the alternative 
plans. Such data should be included together with water-quality information 
so that pollutant loadings can be determined. Without flow-quantity data, it 
is wery difficult to assess the impacts of the alternatives or draw conclusions 
as to preference. For example, the contamination of Mud Slough is attributed 



5-40 



Director, Office of Environmental Affairs, B/Reclamation 2 

to Kesterson Reservoir but no flow data are provided to evaluate loadings 
while under the wet option of the Flexible Response Plan, the assumption of 
selenium immobilization in sediment may be too conservative if flow rates 
are significant. 

Under the Wetland Restoration/Onsite Disposal Plan alternative about 
6,000 acre-feet of ground water is to be extracted annually from 21 wells. 
It appears that this withdrawal will exceed the aquifer underflow of some 
4,000 acre-feet per year. The impact of this drawdown on the aquifer may 
be significant and should be assessed before implementing this alternative. 

We hope these comments will prove useful to you in preparing the Final 
Statement. 




Jafnes F. Devine 



Attachment 



Copy to: District Chief, WRD, Sacramento 
M. Sylvester, WRD, Menlo Park 
( S.E . Hoffman, Program Manager, B/Reclamation, Sacramento 



5-41 



10 



11 



USGS Review Comments on DEIS 
Kesterson Program 
SPECIFIC COMMENTS 



Summary 



Page iii-- Selenium concentrations in groundwater in the vicinity of 
Kesterson Reservoir are greater than background concentrations and exceed 
drinking water standards at several locations (page 4D-10 and figure 4-12). 
Thus, it is not correct to say that selenium has migrated vertically into 
the groundwater in isolated locations. We suggest changing 'isolated' to 
'some' . 

Page viii-- Existing data indicate that the anaerobic environment of the 
sediments in Kesterson Reservoir inhibits selenium from entering the 
groundwater. This inhibition might be restricted to portions of Kesterson 
Reservoir that have clayey sediments because at least two locations with 
sandy sediments have elevated selenium concentrations in the groundwater. 

Page ix-- Beneficial effects of alternative cleanup plans should be mentioned 
as well as negative impacts. 

Introduction: 

Page 1-2 and 1-3-- The source of selenium in Kesterson Reservoir has been 
determined to be from irrigated agricultural areas. No other sources for 
selenium in Kesterson Reservoir have been identified. Thus, it is not 
appropriate to state that most of the selenium came from irrigated agri- 
cultural areas. Presser and Barnes, 1984 and 1985, should be referenced 
here. 

Page 1-2-- Ohlendorf and Saiki did not sample and analyze groundwater. 
Deverel and others, 1984, should be cited for groundwater data. USBR (water 
data) and USDA (vegetation data) should also be cited. 

Page 2-2-- The USGS's study program addresses the sources, distribution, 
transport, and fate of selenium and other constituents in the water and 
soils. Specific study topics include geologic sources of salts found in 
irrigation drainage water, occurrence and mobility of trace elements in soil 
and groundwater, ground-water flow systems and solute transport, and the 
effects of agricultural drainage on surface waters. 

Page 2-6-- We suggest a brief description of the Grassland Water District's 
program to assure that selenium waste-loads reaching the San Joaquin River 
would not be increased through the operation of the interim projects. 



5-42 



Alternatives 



12 



Page 3-3-- The upper few inches of sediment in Kesterson Reservoir is 
probably settled biological detritus (dead algae, wigeon grass, etc.) that 
has high selenium concentrations due to bioaccumulation. 



13 I Table 3-1-- Recommend values be presented as dry weight or wet weight. 

Page 3-5 — Bioassays that test an organism's response to selenium in the 
water are not very meaningful given that the toxicity to wildlife at 
Kesterson Reservoir is due to bioaccumulation through the food web. Why was 

14 not a benthic invertebrate used in the toxicity test? Benthic invertebrates 
are more likely to be affected by selenium in sediment than a fish because 
benthic invertebrates live on or in the sediment. Chronic bioassays are 
also needed. If perfomed, they should be identified. 



15 



20 



22 



16 



17 



18 



Page 3-5-- Molybdenum concentrations in Kesterson Reservoir are four times 
greater than background concentrations. EPA has set a preliminary health 
goal of 70ug/l for daily intake of drinking water (see Table 3.2) not 
100 ug/1 as given in the text. 

Page 3-5-- Define low concentrations. Selenium concentrations should not be 
stated to be low when many observations exceeded the drinking water 
standard. 

Page 3-7 — Selenium concentrations greater than the drinking water standard 
were observed at several locations (page 4D-10 and figure 4-12). Define 
uppennost strata. Should the term be shallow aquifer? There are some areas 
where selenium has migrated vertically. 

I Page 3-7-- Were hazardous waste TTLC's actually expressed in wet weight? 



19 I Page 3-8-- Change 'isolated' to 'some' in the first sentence under Groundwater. 

Page 3-8-- We do not believe it is difficult to determine the source of 
selenium in Mud Slough. Samples could be collected in Mud Slough upstream 
and downstream of Fremont Canal and other potential sources. The PDEIS 
(page 3-4) and later information in the DEIS state that the source of 
selenium in Mud Slough is probably Kesterson Reservoir. 



I Page 3-9 — The walls and bottom of the SLD are covered by mats of attached 
algae. Also, clumps of Nitella sp. are suspended in the water. 



Page 3-9 — The Planning Assumption should include below-ground parts of 
plants (roots, tubers, etc.) because two of the alternative cleanup plans 
involve scraping off surficial sediments. 



5-43 



23 



Page 3-10 — Selenium concentrations in invertebrates, fish, and waterfowl 
should be given. These data were included in the PDEIS (page 3-8 through 3-10), 
Why were these data not included in the DEIS? 



jPage 3-10-- Provide values for gaseous compounds of selenium in air above 
^'^ IKesterson Reservoir. 



25 



26 



27 



30 



31 



Page 3-24-- Successful immobilization also would require mechanisms for 
eliminating volatization of selenium from the bottom muds to the water and 
air and bioaccumulation of selenium in benthic invertebrates. 

Figure 3-3-- Given that selenium appears to be moving into Mud Slough and 
groundwaters north of Kesterson Reservoir, why are there no extraction wells 
proposed on the west and north sides of Kesterson Reservoir? 

Page 3-34-- What evidence is there for an impermeable layer shallower than 
the Corcoran Clay? 

Page 3-42-- Provide the effeciency of Reverse Osmosis treatment for removing 



I Page 3-42 
'^^ |selenium. 



29 iPaqe 3-43-- Will there be pretreatment to remove suspended solids? 
Impacts 



Page 4A-1-- Change artesian aquifer system to regional aquifer system. The 
Corcoran Clay ranges from about 180 feet beneath Kesterson Reservoir to 600 
feet beneath the south end of the SLD. 

Page 4A-2 — The description of Surficial Clay Thickness should emphasize 
that silty sands predominate beneath Kesterson Reservoir. Also, precon- 
struction clay thicknesses are used to describe existing clay thicknesses. 
Some of the clay was removed to build Kesterson Reservoir dikes. We believe 
(LBL, 1985a), concluded that refinement of the clay thickness map is 
needed because the only data for comparison with preconstruction conditions 
are the geologic logs of the monitoring holes recently drilled by the USBR 
and most of these holes are relatively shallow (less than 15 feet) and are 
located along the periphery of the reservoir. As shown on figure 4-3, 
Kesterson Reservoir surficial clays were highly variable in thickness at the 
time the preconstruction sampling was done. This is probably true of 
existing clay thicknesses. Thus, a complete sampling of existing reservoir 
sediments (including many more locations than LBL used) is needed to 
construct an accurate postconstruction map of surficial clay thicknesses. 
The preconstruction map does indicate that about 1/3 of the reservoir had 
clays less than 5 feet thick. If any scraping of these clays was done to 
construct the dikes, little impermeable material would be left to retard 
trace element movement into the shallow, ground-water aquifer. 



5-44 



32 



33 



Figure 4-3 — Why is the source of this figure a USBR 1983 publication when 
the preconstruction information was collected in the late 1960's? Should 
not Luthin be cited? 

Page 4A-3-- EC i's an indication of salinity, not a measure of salinity. 
Give values of TTLC's for hazardous and designated waste. 

Page 4A-4-- We do not believe Brady 1974, "The Nature and Property of Soils" 
has significant application to Kesterson Reservoir sediments because of the 
anaerobic, reducing conditions present in these sediments. Under reducing 
conditions some trace elements such as manganese and beryllium would likely 
become more soluble whereas others like selenium would tend to be transformed 
to less soluble forms. 



35 I Page 4A-4-- Does 165 mg/Kg (dry weight) equal 23 mg/Kg (wet weight)? 
36 



Page 4A-5 — After the word culverts, the last part of the last sentence, 
final paragraph under Areal Distribution of Selenium is not needed. 



Page 4A-5-- Presser and Barnes 1984 and 1985 should be referenced as well as 
Cooke, 1985. The main reason for the decrease in selenium concentrations in 
water from pond 2 northward to pond 11 most likely is biological uptake. 

page 4A-5 — Give reference(s) for the data provided and methods used under 
the headings sediment volume and extent of contamination (See PDEIS, page 
4A-5), 

39 I Table 4-2-- Why was surficial organic material removed? 

Page 4A-7-- Figure 4-5 shows 12 of 35 sample locations had selenium con- 
centrations greater than 100 mg/Kg (dry weight). All values should be 
expressed as either dry weight or wet weight, or, at least, provide a 
conversion factor. The median selenium concentration should be used instead 
of the mean in calculating selenium mass in the SLD. The median is a 
better estimator of central tendency of data when the data distribution is 
skewed or values are highly variable. 

Page 4A-7 — The value of forty two to 60 inches for seasonal high water 
table should be clarified. 

Pages 4A-9 to 4A-14-- This section of the report. Impacts of Alternatives, 
appears to contain speculative statements and the validity of the selenium 
mass balance rates of selenium transformation in Kesterson Reservoir are 
questionable. Unreliable assumptions and conjectures make this attempt 
to quantify selenium levels suspect. A description of what is now known 
would seem to be more appropriate. 



5-45 



43 I Figure 4-7-- Figure A-7 in the PDEIS should be used. 



44 



45 



46 



47 



48 



Page 4A-14-- Estimates of the amount of selenium available for groundwater 
transport are based on calculations in Impacts of Alternatives. These 
estimates are speculative and unreliable. 

Page 4A-18-- The effect of an aerobic, alkaline environment on selenium 
mobilization and transport should be discussed. Percentage increases in 
leaching of selenium from sediment into groundwater appear too speculaive. 
A description of whether or not it will increase or decrease would be 
appropriate. 

Figure 4-8-- This figure is not understandable. It shows that selenium 
concentrations increase with cumulative soil volume. Is that what the 
figure was intended to show? If so, what does it mean? Also, the note 
related to the figure seems incorrect. 

Page 4B-1-- Monthly average cl imatological data were presented in table B-I 
of the PDEIS. This information was useful. It should be included in the 
DEIS. 

Page 4B-8 — Location of air samplers should be described or shown in a 
figure. Especially important is the distance that the gas sampler is from 
the water surface. 



Tables 4-10 and 4-11-- We believe the information in these tables is 
49 I speculative, as it is based on questionable assumptions and conjecture. 



i 

i 



50 



51 



52 



53 



54 



Page 4B-18-- We believe it is inappropriate to conclude that selenium 
volatization from surface water would cease under the no action alternative. 
Volatile selenium compounds would probably still be in bottom sediments and 
could diffuse through the water column to the atmosphere. 

Page 4B-28 — The sources of the dimethyl selenide would primarily be from 
sediment, detritus, and living vegetation; not from the water. 

Pages 4D-2 and 4D-3-- Information in the PDEIS (pages 40-3 and 4D-4) was not 
included. The equation and data used to calculate ground-water velocity 
help the reader assess the reliability of the calculation. Why was 
reference to Luthin, 1966, deleted? 

Page 4D-3-- Provide water-quality data that suggest downward flow is occurring 
within the shallow aquifer below Kesterson Reservoir. 

Page 4D-8-- Table 4D-7 shows that molybdenum exceeded 70ug/l in 177 samples 
from 22 wells. This is about 27 percent of the observations. Is it 
appropriate to dismiss molybdenum as a potential hazard to beneficial uses 
because the mean concentration did not exceed the ambient water-quality goal 
of 70ug/l? 



5-46 



I Table 4-24 — Information in this table contradicts information in table 4-23 
and is not needed, as it only repeats information in tables 4-22 and 4-23. 



56 



Page 4D-10-- Table D-7, page 4D-14 in the PDEIS is needed to show what is 
described in the text. The explanation of table D-7 data given in the PDEIS 
on page 4D-13 is also needed. Explain how the amount of selenium in the 
ground water was calculated? 



57J Figure 4-12-- Show pond numbers. 

SSJPage 4D-11-- We believe USBR 1985a is the correct reference. 

59| Page 4D-12-- Provide data from wells adjacent to the SLD. 

(Page 4D-13-- Provide evidence to support the statement that the recharge 
mound would dissipate within one year. 

[Page 4D-16 — The incorrect table is referenced. Table 4-20 only provides 
(location and use of wells. 

621 Figure 4-14-- What infonmation was used to produce this figure? 



63 



Figure 4-15-- A quantitative mass balance for selenium partitioning among 
water, sediment, and air does not appear appropriate. Assumptions on how 
much selenium is transferred from one box in the diagram to another are 
not well founded. Presentation of a conceptual model would be more 
appropriate. Assigning numbers based on conjecture is not scientifically 
credible and only provides an illusion of accuracy. 



64JPage 4D-17-- Define ponded groundwater. 



65 



Page 4D-17 — Organic selenides and acid form H2Se should be discussed 
under the heading Fate of Contamination. Change absorb to adsorb in the 
third sentence. 



Table 4-26-- Values in the last column of this table have little usefulness 
I because they are based on conjecture and have questionable validity. 

[Table 4-27 — This table should be deleted. Numbers given are based on 
67 ' conjecture and have little or no validity. 



68 



69 



Page 4D-20-- Offsite contamination has occurred, but it is restricted to 
Mud Slough and areas immediately adjacent to Kesterson Reservoir on the 
north and east. 

Page 4D-20-- The effect of ground water seepage into the SLD on selenium 
mobility in the SLD is not known. Selenium mobility would depend on whether 
the ground water is aerobic or anaerobic, and on the pH and ionic 
composition of the ground water. 



5-47 



70 



78 



79 



80 



71 



72 



73 



74 



75 



Page 4D-22-- Why use the deep aquifer as a supplemental water supply for 
Kesterson Reservoir if pumping from this aquifer will produce a downward 
gradient between the upper and lower water-bearing zones? The downward 
gradient could increase the potential for degradaton of this regional 
aquifer. Why not tap just the upper water-bearing zone? 

Page 4D-24-- The amount of selenium in the groundwater is based on mass 
balance calculations presented earlier in the DEIS. These calculations are 
highly speculative (see previous comments). 

Page 4D-24-- The dominant selenium species in drainwater is selenate 
(Presser and Barnes, 1984, table 3). Kauffman et al , 1984, reported results 
for acid pH's. Under alkaline conditions selenium would tend to remain in 
the selenate form. 

Page 4D-26 — Selenium concentrations in Kesterson Reservoir average 200ug/l. 
Thus, an average estimate for selenium transport in groundwater is obtained, 
not a conservative estimate. 

Page 4D-26 — The pond option would increase flow rates because the hydraulic 
head would be increased due to increased water levels in Kesterson Reservoir 
(see page 4D-24). 

Page 4D-27 — Selenium concentrations in ground water average 9ug/l (table 
4-22). Thus, extracted water would be expected to average 9ug/l. Change 
conservative estimate to reasonable estimate (also on page 4D-29). 

Page 4D-28 — If selenium is immobilized in the surficial clays, groundwater 
removal combined with recharge would not flush selenium from the clays to 
the sandy aquifer. Why would selenium undergo reduction in the sandy 
aquifer if it is already reduced in the surficial clays? 

Page 4D-29-- Extraction wells on the north and west sides of Kesterson 
^^ I Reservoir would also be needed (figure 4-12). 



Page 4D-30-- A perched zone does not exist. In the vicinity of Kesterson 
Reservoir, the shallow aquifer is hydraul ical ly connected to the upper 
water-bearing zone of the regional aquifer. Slow movement of water from the 
shallow aquifer into upper water-bearing zone of the regional aquifer could 
also explain differences in the water-quality between the aquifers. 

Page 4E-1-- Features used to delineate the regional surface water setting 
are not shown or, at least, not highlighted on figure 4-16. Kesterson 
Reservoir was completed in July, 1972 (San Luis Drain Chronology, USBR, 
January 18, 1985). Is not local runoff agricultural return flow? 
Substitute irrigation supply and surface return water for fresh water in the 
3rd sentence of the 3rd paragraph. The average quantity of water delivered 
to Kesterson Reservoir via the SLD from 1981-84 should be given instead of 
from 1978-84. Agricultural drainage water did not makeup the majority of 
the water in the SLD until 1981. 



5-48 



81 



83 



84 



85 



86 



87 



88 



89 



90 



91 



92 



8 

Page 4E-3-- According to table 4-29, the maximum amount of selenium recorded 
in the surface water system outside of Kesterson Reservoir and the SLD was 
28ug/l at Mud Slough. Presser and Barnes 1984 and 1985, Izbicki 1984, and 
Gilliom, 1986, have data that should be included in the discussion of 
surface water. 



I Page 4E-10-- Why would TDS increase during winter-spring and decrease during 
^2 summer-fall? 



Page 4E-11-- Molybdenum concentrations did not exceed the estimated 
permissible ambient criterion of 70ug/l. 

Page 4E-15-- Ground water seeping into the SLD will keep the sediments 
anaerobic and selenium immobile only if the ground water is anaerobic and 
has a neutral to acid pH. 

Page 4E-16-- Clean water added to the SLD south of Bass Avenue probably 

would not prevent selenium mobilization. Benthic invertebrates might 

remobilize selenium via bioaccumulation. If the clean water is aerobic, it 

will oxidize the sediments and remobilize selenium. 

Pages 4E-16 and 4E-18-- If the water quality of Kesterson Reservoir 
improves, the water quality of Mud Slough and ground water in the vicinity 
of Kesterson Reservoir should also improve. 

Page 4E-17 — It is not known if selenium is immobilized in SLD sediments. 
At least surficial sediments might be aerobic and contain a benthic 
invertebrate community. 

Page 4F-6-- The sides and bottom of the SLD are covered with thick mats of 
attached algae. Also, clumps of Nitella species are suspended in the water. 

Page 4F-9 — How was it determined that oxidation of previously reduced forms 
of selenium in the soil would yield about 80 percent selenite and 20 percent 
selenate? Chapter 4, Topography, Geology, and Soils, does not present any 
information to support this statement. 

Page 4F-13-- Concentration thresholds for boron-tolerant crops seem very 
low. These threshold values should be checked to verify if they are in 
the ppb range. It appears that all, values given should be ppm, not ppb. 

Page 4F-14-- Dr. Glenn Hoffman with the Agricultural Research Service, USDA, 
has collected and analyzed vegetation from Kesterson Reservoir, the pilot 
desalination plant east of Los Banos, and irrigated fields along the west 
side of the SLD south of Mendota. These data should be included in the 
discussion of selenium concentrations in vegetation. 

Page 4F-20-- Algae could also take up selenium directly from the water. 



5-49 



93 



94 



95 



96 



97 



98 



99 



100 



101 



102 



103 



104 



105 



Page 4F-22-- The effect of herbicides on surface- and ground-water quality 
is not considered in the DEIS. 

Page 4G-2-- Selenium concentrations in fish from Volta WMA should also be 
given (Ohlendorf, 1985). 

Page 4G-3-- The conversion factor from wet weight to dry weight for fish 
tissue is 3.6 X wet weight = dry weight. Thus, 30 ppm wet weight equals 108 
ppm (dry weight), not 135 ppm (dry weight). 

Page 4G-7-- How was the background concentration of 3 ppm (dry weight) 
determined? 

Page 4H-31-- Immobilization of selenium in sediment would not occur if 
cattails are encouraged to grow in Kesterson Reservoir because cattails take 
up selenium. Their roots are shallow and, thus, are exposed to the highest 
selenium concentrations in the sediment. 

4N-1-- Why are beryllium and nickel considered possible contaminants of 
concern? Describe their significance related to public health. 

Page 4N-1-- The average of selenium concentrations in the SLD sediment north 

of Manning Avenue is 84 mg/kg (dry weight) in the upper 3 inches. This 

should be compared with the average selenium concentration in the upper 2 

inches (not the upper 5 inches) of sediment at Kesterson Reservoir 
(55 mg/kg, dry weight). 

Page 4N-2-- The study of agricultural crops was determined to be invalid 
by the Interagency Technical Coordination Committee on the San Joaquin 
Drainage Basin and should not be included in the DEIS. 

Page 4N-2-- State the reason why cattle on the Frietas property adjacent to 
Kesterson Reservoir on the east were not sampled. 

Page 4N-3-- Selenium concentrations given are for drinking water or 
drinking-water supplies? 

Page 4N-3-- Selenium levels reported in the Selected Minerals and Food 
Survey were in mg/day or ug/day? 

Page 4N-16-- Describe or show the location of upgradient and downgradient 
wells and refer to information in figure 4-12. 

Page 4N-30-- Some exposure to selenium might result from salt crusts on 
vegetation. These crusts are probably mostly composed of Na2S04 with some 
Na2Se04. Presser and Barnes, 1984 reported that a salt crust from pond 11 
contained 1.8 ppm Se (dry weight). 



5-50 



Response to Comments of the U. S. Geological Survey 

The suggested changes are editorial in nature and do not 
change the essential conclusions of the Draft EIS. The 
USER and its consultants have attempted to organize the 
Kesterson Program EIS in a manner that is both informative 
and easy to follow. It is recognized that other editorial 
approaches also could have accomplished these goals. 

Please see the discussion of FRP risks in Chapter 3 of this 
Final EIS. The goal of the Draft EIS was to summarize the 
major literature on selenium toxicity to wildlife and the 
extent of contamination at Kesterson Reservoir for a gener- 
al audience rather than to provide a detailed analysis. 
Few previous studies have addressed in detail the extent of 
contamination of major food web elements at Kesterson 
Reservoir. Studies of the extent of contamination of 
various invertebrate taxa at different ponds and seasons 
were initiated by LBL in fall 1985. These studies will be 
expanded as part of the monitoring progreim for the FRP. 
Major trophic elements of the Kesterson Reservoir food web 
will be sampled including: 1) producers (vascular plants in 
both wet and dry habitats, as well as diatoms and filamen- 
tous algae), 2) consumers (free-swimming, epifaunal, and 
benthic invertebrates, fish, birds, and mammals), and 
3) decomposers (macroinvertebrates) . The USER expects that 
these ongoing studies will provide a more complete under- 
standing of spatial and temporal variations of contaminants 
at various trophic levels of the Kesterson food web. 

The proposed Kesterson Reservoir water operation and ex- 
pected water quality are described as part of the proposed 
action. Effects of Kesterson Reservoir on flows and water 
quality in Mud Slough have been identified as a data gap 
and the USER is currently conducting a field investigation 
to determine the source of flows and contaminants in Mud 
Slough. It is expected that with application of clean 
water to Kesterson Reservoir, there will be no contamina- 
tion of Mud Slough from Kesterson Reservoir. 

The pumping rates for the extraction well system specified 
in the Draft EIS exceed the underflow to capture the con- 
tamination along the Reservoir perimeter between the pro- 
posed extraction wells. Once captured, the pumping rates 
could be reduced to equal the underflow. Before imple- 
menting such a system, long-term pumping tests in pilot 
extraction holes would be required to identify the hydro- 
logic properties of the underlying strata, and an analyti- 
cal or numerical model would be required to address the 
impacts of the pumping on the regional water levels. This 
study is not necessary for understanding the impacts of the 
Onsite Disposal Plan in this Final EIS, since the 
extraction well system specified in the Draft EIS is not 
part of the Onsite Disposal Plan as currently defined. 



5-51 



5. The USER agrees with the suggested change. The errata 
sheet indicates the suggested revision. 

6. Selenium may be moving into the shallow groundwater where 
sandy sediments are exposed; however, evidence suggests 
that the region's groundwater has the capacity to reduce 
these soluble selenium species to less soluble species. 

7. Page ix is a concise summary of impacts only. More exten- 
sive discussions of beneficial effects appear throughout 
the impact sections; however, note that major beneficial 
impacts are included on p. ix (e.g., most alternatives 
"reduce risks of offsite groundwater contamination"). 

8. Presser and Barnes (1984, 1985) indicate that the source of 
selenium at Kesterson Reservoir is irrigated agricultural 
land. The errata sheet indicates the suggested change. 

9. The citations for Ohlendorf and Saiki are in error. 
Sources of vegetation and groundwater data are presented in 
Draft EIS Chapters 4D and 4H, respectively. 

10. The USBR appreciates this clarification of U. S. Geological 
Survey's (USGS') role in the SJVDP. 

11. This program is currently under development by the Grass- 
lands Water Task Force. 

12. The USBR agrees with this assessment. Organic detritus is 
discussed in Chapter 4A. 

13. The TTLC criteria are based on wet weight. The range of 
concentrations of Kesterson Reservoir soil samples is in 
terms of dry weight because moisture content information 
was not available for all these samples. 

14. The fathead minnow bioassays described were conducted for 
the purpose of waste classification. The procedures fol- 
lowed are those described in Title 22 of the California 
Administrative Code. Benthic invertebrates are not speci- 
fied as part of this test. Results of the LBL surveys 
indicate that true benthic invertebrates are in very limit- 
ed abundance at Kesterson Reservoir, suggesting that this 
potential food chain exposure pathway may have limited 
importance at Kesterson Reservoir. See discussion of FRP 
risks in Chapter 3 of the Final EIS. 

15. The source of the 70 yg/l criteria for molybdenum, as 
listed in Table 4-22, is the EPA as cited by Marshack 1985 
(see References section of the Draft EIS) . These criteria 
are listed as the "Estimated Permissible Ambient Goal for 
(human) health effects." The errata sheet indicates the 
suggested correction. 



5-52 



More recently, EPA listed an AADI (Adjusted Acceptable 
Daily Intake) of 100 pg/1 molybdenum to protect human 
health, as reported in the Federal Register , Vol. 50, 
No. 219, November 13, 1985. Also reported in this Feder - 
al Register are the federal health advisories for children 
and adults over a 10-day exposure period, which are 270 and 
950 pg/l molybdenum, respectively. 

The recommended maximum concentration of molybdenum in 
irrigation waters for continued use on all soils, based on 
animal toxicities from forage bioaccumulation of this 
element, is reported to be 10 ug/l (National Academy of 
Sciences 1973) . 

16. The USER agrees that the relevant passage could benefit 
from clarification. A clarification has been included on 
the errata sheet. 

17. The uppermost stratum is defined as the clayey layer under- 
lying the Reservoir. The clay layer is patchy and inter- 
fingered with silty sand ranging up to 20 feet thick. The 
average selenium concentration in the groundwater in this 
interval is 18 ug/1. Below this interval, the average 
concentration is roughly 6 pg/1. 

Selenium has migrated vertically in some areas. This 
correction has been included on the errata sheet. 

18. Hazardous waste TTLCs are expressed in wet weight in 
California Administrative Code, Title 22, Div. 4, Chap. 30, 
"Minimum Standards for Management of Hazardous and Extreme- 
ly Hazardous Wastes." 

19. The errata sheet reflects the suggested change. 

20. A study of Mud Slough contamination has been included in 
the surface water monitoring program (see proposed action 
description in Chapter 2 of the Final EIS) . 

21. The USER agrees with this comment. The interior sides of 
the SLD, although made of concrete, support extensive 
growth of filamentous algae in some areas. The muddy 
bottom of the SLD supports additional filamentous algae as 
well as scattered large clumps of Nitella suspended in the 
water. Diatoms and other phytoplankton are also abundant 
in SLD water. 

22. The Draft EIS assumes that contaminated sediments and 
soils, if removed, will be classified as designated waste 
(p. 3-8) . It is true that excavation of the top 6 inches 
of sediments and soils will also remove below-ground plant 
parts. Average selenium concentrations in below-ground 
plant parts (64 mg/kg) are well below the 100 mg/kg crite- 



5-53 



rion for hazardous waste. Excavating below-ground plant 
parts together with sediments and soils therefore will not 
change the planning assumption regarding classification of 
sediments and soils as designated waste. 

23. Data on selenium concentrations in invertebrates and water- 
fowl are contained in Chapter 4H of the Draft EIS. Data on 
selenium concentrations in fish are contained in Chapter 4F 
of the Draft EIS. These data were not repeated on pp. 3-9 
and 3-10 of the Draft EIS because these pages are intended 
to provide a short summary of the extent of fish and wild- 
life contamination. 

24. These data are presented in Table 4-9 of the Draft EIS, and 
are not repeated on p. 3-10 because this page is intended 
to provide a short summary of air quality data. 

25. Please see the discussion of FRP risks in Chapter 3 of this 
Final EIS. 

26. The preliminary extraction network was designed to inter- 
cept underflow due to regional flow and applied surface 
water. Extraction wells to the north and west were not 
included for the following reasons: 1) the extraction 
system will reduce seepage to Mud Slough by creating a cone 
of depression and altering flow patterns; and 2) the selen- 
ium concentration of the recycled water will be much less 
than the influent drain water. 

27. The USER regrets that the term "impermeable" was not used 
precisely. However, the conclusion drawn in the Draft EIS 
remains valid. Geophysical and lithologic logs from the 
USER and LEL monitoring wells suggest that a clay layer of 
up to 10 feet thick exists roughly 70 feet below ground 
surface. This and other less continuous clay layers may 
restrict the vertical flow of groundwater. 

28. Reverse osmosis, depending on the process, is expected to 
remove up to 95 percent of selenium. 

29. Pretreatment will consist of softening and filtration. 
Suspended solids will therefore be removed. 

30. The USER agrees with the correction. The errata sheet 
indicates the suggested change. 

31. P. 4A-2 does indicate the presence and approximate abun- 
dance of silty sands beneath Kesterson Reservoir. 

The resolution of the clay thickness map is not intended 
for performing detailed analysis of the interactions be- 
tween the groundwater system and the Reservoir. LEL also 
recommended collection of additional clay thickness data. 



5-54 



However, LBL found "overall agreement" between recent USER 
well log data and the preconstruction clay thickness map, 
and pointed out that the preconstruction map "provides a 
good starting point for a more detailed investigation (of 
surface and groundwater hydrochemistry) " (LBL 1985a). 

The USER believes that the map provided adequate infor- 
mation for the conceptual models used to compare relative 
impacts from the proposed alternatives. As explained in 
Chapter 4D of the Draft EIS, the risk to groundwater from 
the proposed action is slight. 

32. Luthin may also be an appropriate citation, however, the 
referenced citation (USER 1983b) provides a good summary of 
the original work done by the Department of Water Resources 
(DWR) along with a well-drafted map. 

33. The USER agrees with the correction. The errata sheet 
indicates the suggested change. TTLC values for hazardous 
and designated wastes are listed in Table 3-1. 

34. Brady (1974), although not applicable to selenium mobility, 
provides a relatively nontechnical explanation of the 
effects of pH on manganese solubility that would be 
understood by the average reader of the Draft EIS (Brady 

[1974] was not used in the Draft EIS to evaluate selenium 
behavior in soils) . Reducing conditions will result in 
manganese (II) being the dominant oxidation state. Very 
little information is available on precipitation/dissolu- 
tion and adsorption/desorption mechanisms for manganese 
(II); however, pH appears to influence manganese thermo- 
dynamics strongly under both reducing and oxidizing condi- 
tions (Rai et al. 1984). In addition, the solubility of 
beryllium compounds in aqueous environments decreases 
rapidly with increasing pH (Rai et al. 1984) . It is 
expected that selenium will be mobile in the alkaline 
aerobic conditions that occur in the surface waters at 
Kesterson Reservoir but will be immobile in the acidic 
anaerobic conditions that occur in Kesterson Reservoir 
muds . 

35. The data were reported on both a wet- and a dry-weight 
basis. The reported values of 165 mg/kg and 23 mg/kg were 
the dry-weight and wet-weight means, respectively. 

36. The sentence referred to is: "The highest levels were in 
the wet areas of Ponds 1, 2, and 3 near inlets and culverts 
and are indicated by the high average values for the cat- 
tails and bulrush and open water cover types." The com- 
menter suggests that the sentence be ended after the word 
"culverts." However, higher selenium levels associated 
with open water and cattail/bulrush areas are shown in 
Table 4-2 and are, therefore, referenced in the text. 



5-55 



37. Presser and Barnes (1984, 1985) provide data that support 
Cooke's observations about a decline in surface water 

- concentrations of selenium going north away from the inlet. 
The reference in this paragraph to "...reduction of the 
soluble selenium by microorganisms which settle out..." is 
another way of expressing the existence of biological 
uptake. 

38. The references for "sediment volume" are correct (USER 
1985e,h) . The reference for "extent of contcimination" was 
inadvertently left out. The errata sheet indicates the 
addition of the USER 19851 reference. 

39. The sediment sampling program had several objectives: to 
determine the areal extent of selenium for planning exca- 
vation alternatives, and to estimate the average and maxi- 
mum selenium concentration for purposes of waste classifi- 
cation. The upper 6 inches of soil were selected as the 
appropriate sampling depth because that is the minimum 
depth that could be efficiently excavated. 

The surficial organic layer was removed for the following 
reasons : 

o Preliminary analyses indicated that this fraction 
had high selenium levels; so it was decided to 
sample the "organic detritus" separately. Moreover, 
during vegetation sampling, the thick mats of 
Nitella were collected and analyzed for selenium. 

o Comparison ot mats of decayed organic material from 

one sample site with mineral soil from another site 

in the same pond or a different pond would not have 

provided useful comparative data about soil con- 
tamination. 

o Inclusion of various amounts of surficial organic 
material would not have allowed the calculation of 
selenium mass in the (excavatable) upper soil since 
bulk density would have been too variable. 

40. Selenium concentrations shown in Figure 4-6 were all sam- 
pled in the upper 3 inches. Only dry weights were report- 
ed. To convert selenium concentration to mass of selenium 
in a known volume of wet sediment, the wet-weight concen- 
tration or moisture content of the sample was needed. It 
should be noted that sediments are not evenly distributed 
in the drain but have accumulated only in some areas (next 
to checks and bridges) to depths of 4-6 feet. The SLD 
sediment samples collected in June 1985 by CH2M Hill were 
analyzed for moisture content (as well as total selenium 
for various depth increments) , so these samples were used 
to calculate selenium mass in sediments along the drain. 
These samples were not used in Figure 4-6 because the depth 
increments were generally 12 inches, not 0-3 inches. 

5-56 



As mentioned above, the data used to calculate selenium 
mass were not those shown in Figure 4-6. The wet-weight 
data used for mass calculations were more normally dis- 
tributed. The median was about 10 mg/kg wet weight com- 
pared to the average of 12.8 mg/kg wet weight. The stan- 
dard deviation was about 9 mg/kg; thus, the median is well 
within the confidence interval around the estimate of the 
mean. The selenium mass calculated from mean wet-weight 
concentration and sediment volume was deducted from the 
cumulative selenium input into the SLD to estimate the 
amount of selenium that entered Kesterson Reservoir. The 
reliability of this estimate is low, as indicated in Ta- 
ble 4-3. 

41. The typical depth from the soil surface to saturated soil 
during the wet season for these soil series ranges from 42 
to 60 inches. Soil series descriptions are based on typi- 
cal conditions. Actual depth to seasonal high water table 
on the Gallo property may be different. No field inves- 
tigations were conducted on the Gallo tract for the Draft 
EIS. 

42. The use of speculative rates versus qualitative comparisons 
to compare potential selenium mobility for the different 
alternatives was a subject of much debate during the pre- 
paration of the Draft EIS. It was decided to use conserva- 
tive interpretations of values for transformation rates 
(oxidation, reduction, adsorption, volatilization) that 

were found in the literature. This enabled development of 
a simple conceptual model with which the impacts of per- 
manently wet, permanently dry, or wet and dry cycles at the 
surface could be compared in terms of selenium leaching. 
Although this resulted in speculative numbers, the relative 
impacts of alternatives are more readily understandable 
with examples of a quantitative comparison. 

The conceptual model, discussed in Chapter 4D (Ground- 
water) , provided the framework for rough quantitative 
comparisons of selenium fluxes for the alternatives con- 
sidered. It was strongly emphasized in both Chapters 4A 
and 4D that these are very rough approximations of actual 
rates that may occur at Kesterson Reservoir. For example, 
on p. 4A-12: "...It should be noted that these (trans- 
formation rate) estimates are oversimplifications of very 
complex processes that are poorly understood.... These 
rates are from various sources and are based on conditions 
not necessarily the same as at Kesterson Reservoir." 

43. The comment references two different schematic illustra- 
tions of selenium biogeochemistry . Although both have 
merit. Figure 4-7 in the Draft EIS is the more compre- 
hensive. 



5-57 



44. The use of assumptions and conceptual models to the extent 
they are speculative is addressed in response to comment 42 
above . 

45. The effect of an aerobic, alkaline environment on selenium 
mobilization and transport is discussed in the Draft EIS on 
pp. 4A-12 to 4A-14. It is expected that selenium will be 
mobile in the alkaline aerobic conditions that occur in the 
surface waters at Kesterson Reservoir but will be immobile 
in the acidic anaerobic conditions that occur in Kesterson 
Reservoir muds. 

46. The USER agrees that Figure 4-8 requires clarification. It 
is presented to show how much soil volume would have to be 
excavated given a particular maximum allowable selenium 
concentration in the upper 6-inch layer. The errata sheet 
indicates necessary changes in the language of the note to 
clarify its meaning. 

47. Monthly average climatological data, although available, 
were not included in the Draft EIS because these data did 
not materially assist the analysis of environmental im- 
pacts. At Kesterson Reservoir, average annual precipi- 
tation is about 60 inches. Average annual rainfall is 
about 60 inches. 

48. The USER agrees that the suggested changes would provide 
useful clarification. The locations of the selenium air 
samples were described at the bottom of Table 4-9 (Draft 
EIS p. 4B-9) . Water surfaces in the 12 shallow ponds vary 
according to the volume of water stored in the Reservoir. 
Therefore, exact distances of the samples to the water 
surfaces will vary. The samplers are approximately 10-20 
feet above the average pond elevation. The location 
descriptions in Table 4-9 can be made more precise by 
referencing relationships to the closest ponds. The errata 
sheet indicates these changes. 

49. The USER believes that the information contained in Tables 
4-10 and 4-11 of the Draft EIS represents reasonable esti- 
mates of air quality emissions and impacts based on the 
data available at the time of the analysis. Assumptions 
used in the analysis are stated in the text. 

50." The conclusion on p. 4B-18 of the Draft EIS was that selen- 
ium volatilization from selenium-contaminated surface 
waters would cease because selenium-conteiminated surface 
water would not be added to the Reservoir under the No- 
Action Alternative. Volatile selenium components may 
continue to be released from the sediments to surface 
water, and could be released to the atmosphere. See also 
discussion of major issues in Chapter 3. 



5-58 



51. The USER agrees that the sources of dimethyl selenide in 
the reverse osmosis plant ponds are the selenium-contami- 
nated plant and detrital material contained in the water 
and not the water itself. This was discussed in the Draft 
EIS on p. 4B-28. The conclusion in this section remains 
the same. 

52, The USER agrees that the equation and data used in calcu- 
lating the average linear groundwater flow velocity, as 
well as the Luthin (1966) reference, may prove helpful to 
technical reviewers in understanding the conclusions 
reached in the Draft EIS. The equation is: 

Ki 
n 

where v = average linear groundwater velocity (feet/day) 
K = permeability (feet/day) 
i = hydraulic gradient (feet/ feet) 
n = effective porosity (fraction) 

The hydrogeologic data to evaluate this equation are listed 
in the following table. 



Kesterson Data 



Parameter Value 



Permeability of the shallow aquifer 26-310 feet/day 

(mean = 115 feet/day) 

Porosity of the shallow aquifer 0.25-0.50 

Maximum normal water elevation in 78 feet 
Kesterson Reservoir 

Elevation of Salt Slough 62 feet 

Distance between Kesterson Reservoir 

and Salt Slough 7,100 feet 



Sources: Freeze and Cherry (1979); LBL (1985a); USER (1985c) 



53. Statistics on the vertical distribution of the constituents 
summarized in Table 4-24 of the Draft EIS are presented 
below. This table was constructed by calculating the 



5-59 



statistics on water quality data collected between May 1984 
and November 1985 from wells grouped according to screened 
interval midpoint elevations (20-55 feet, 55-65 feet, and 
65+ feet). These data suggest that arsenic, boron, chrom- 
ium, copper, molybdenum, nickel, and selenium are migrating 
in some locations vertically from the Reservoir into the 
shallow groundwater. 



Average Concentration (pg/l) Versus Elevation 
Elevation (feet) 



Chemicals 


20-25 


55-65 




>65 


Arsenic 


4.9 


4.5 




2.6 


Boron 


17,904 


14,098 


10 


,176 


Cadmium 


1.2 


1.1 




1.5 


Chromium 


14.1 


9.4 




4 


Copper 


13.1 


11 




5.5 


Lead 


5.3 


5.6 




13 


Mercury 


0.15 


0.12 




0.13 


Molybdenum 


66.8 


68.7 




22.7 


Nickel 


44.4 


31.2 




14.8 


Selenium 


17.9 


6.1 




5.7 


Silver 


1.2 


1.1 




2.2 


Zinc 


85.6 


199.9 


2 


,826.7 



Source: USER (1985g) . 

Notes: 

Elevation refers to the elevation of the midpoint of the 
screened interval in feet above MSL. As a reference only, the 
elevation of the bottom of Kesterson Reservoir is approximately 
73 feet above MSL. 

Less than detection is set to detection for this analysis. 

Samples from steel-cased wells were included in the statistics. 



54. Molybdenum was not considered as a potential hazard to 
beneficial uses because the average concentration did not 
exceed the estimated ambient goal and because measured 
molybdenum concentrations in the sediments are low. See 
Table 3-1 in DEIS. Therefore, molybdenum levels in the 
groundwater will improve when drainwater deliveries to 
Kesterson Reservoir cease. 



5-60 



55. Table 4-24 was included to provide a direct comparison 
between background and Kesterson Reservoir water quality 
data. The number of observations for data presented in 
Table 4-24 is shown in Table 4-22. The apparent discre- 
pancies between Tables 4-23 and 4-24 (e.g.. Table 4-23 
shows that the cadmium criterion of 6.9 yg/1 was exceeded 5 
times in steel-cased wells 21 DN and ER81M, whereas Table 
4-24 states the same criterion was not exceeded) result 
because Table 4-24 excludes cadmium, lead, and zinc data 
for steel-cased wells. The exclusion of these constituents 
is acknowledged in Note "d" of Table 4-24. 

56. The qualitative analysis presented in Table D-7 is based on 
the conceptual model described in the text of the Draft 
EIS, pp. 4D-16 to 4D-20. 

57. Pond numbers are provided in Figure 4-11 of the Draft EIS. 

58. The correction has been included on the errata sheet. 

59. Selenium data collected by the USER in December 1984 for 
wells located along the SLD are shown in the following 
table. The USER is continuing an investigation of shallow 
groundwater along the SLD to evaluate seepage from the 
drain. 



Well Location 



8S/10E-26P1 
IIS/IIE-IMI 
11S/12E-7E1 
11S/12E-22N5 
11S/12E-26G5 
12S/13E-5C5 
12S/13E-5C6 
12S/13E/13D2 
13S/14E-3M2 
13S/14E-3M4 
13S/15E-19M2 
13S/15E-19M3 
13S/15E-5E1 
13S/15E-5E2 
13S/15E-20R1 
13S/15E-20R3 
17S/17E-3N2 









Selenium 




Selenium 


Level 


Concentration 


Well Name 


Well De 


ipth 


(yg/1) 


^ ^ 


? 




<1 


MD-156 


16 




<1 


MD-158 


16 




<1 


RW-3 


15 




<5 


RW-7 


15 




32 


RW-15 


15 




48 


RW-16 


15 




<5 


RW-2 2 


15 




2 


TR-2E 


20 




13 


TR-2D 


20 




37 


TR-3E 


20 




1 


TR-3C 


20 




29 


TR-5A 


20 




36 


TR-5E 


20 




15 


TR-8A 


20 




8 


TR-8C 


20 




27 


TR-19B 


20 




2 



5-61 



Regional selenium data for the SLD service area, for com- 
parison, are provided in a USGS report by Deverel et al. 
(1984) . 

60. The groundwater mound observed in April 1985 was simulated 
by injecting a total of 4,000 acre-feet/year of water into 
110 wells located in areas where the clay layer underlying 
the Reservoir is thin or absent. Once the mound was simu- 
lated, the water was turned off and the regional gradient 
reestablished in 1 year. This model may underestimate the 
length of time required for reestablishment of the regional 
gradient because it does not take into account the effect 
of clay thickness heterogeneity. This model did not 
incorporate the fluctuation in the regional water table 
(from 8 feet below to 1-2 feet above ground surface). 
These fluctuations would most likely decrease the time 
required for pre-Reservoir conditions to reestablish. 

61. Table 4-20 is incorrectly referenced. The correction has 
been included on the errata sheet. The correct table was 
deleted from the Draft EIS; however, the data are included 
in the response to comment 52. 

62. Figure 4-14 is based on pre-1976 annual maximum water level 
data from 15 wells surrounding the Reservoir and on a 
1-foot postconstruction land surface contour map of the 
Reservoir. 

63. A conceptual model with which to compare the various alter- 
natives was required for the Draft EIS. The conceptual 
model developed for this comparison is explained in the 
Draft EIS (pp. 4D-16 to 4D-20) and is summarized in Figure 
4-17. Because the data presented in Tables 4-7 and 4-27 
are based on a conceptual model and on transformation rates 
not specific to Kesterson Reservoir, a sample calculation 
is included in Figure 4-17. As a result, readers may 
reevaluate the assumptions and transformation rates, 
recalculate the results, and form their own conclusions. 
The USER believes that although this approach is conceptu- 
al, it is a credible method for presenting critical but 
uncertain data when a decision must be made. 

64. Although not precise, the term "ponded groundwater" refers 
to surface water that has resulted from rising groundwater 
(i.e., water that has moved up through the contaminated 
soil and sediments) . 

65. The fate of organic selenides is addressed in the soils and 
air quality sections of the Draft EIS, Chapters 4A and 4B, 
respectively. The correction has been included on the 
errata sheet. 



5-62 



66. The total amount of selenium in sediments and detritus is 
based on an intensive sampling survey conducted in November 
1985. The amount of selenium in each pond, therefore, is 
not con3ecture. However, without specific knowledge on the 
speciation of this selenium, it was assumed that this 
selenium is reduced in the bottom sediments of the ponds. 

The data in this table are the initial conditions used to 
evaluate the different alternatives. The USBK has provided 
these data so that the public may independently review the 
selenium calculations on which the conclusions in Table 4-7 
are based. 

67. The validity of the assumptions and the purposes for which 
they are provided are discussed in the responses to com- 
ments 56, 63, and 66. 

68. The USER believes that, based on the investigations con- 
ducted in preparation of the Draft EIS, the categorization 
of contamination on p. 4D-20 is correct. Results of 
further investigations currently being conducted by the 
USER may indicate offsite contamination either via 
groundwater or Mud Slough. 

69. The USER believes that, based on the investigations con- 
ducted in preparation of the Draft EIS, the statement con- 
cerning selenium mobility is correct. However, as these 
conditions will be similar to past conditions, the impacts 
of this alternative should be less than significant (i.e., 
available data do not suggest that selenium from the SLD 
has affected groundwater quality in the vicinity of the 
drain although further investigation being conducted by the 
USER may indicate seepage into or out of the SLD in some 
areas) . 

70. The proposed action, as described in the Final EIS, will 
use the upper water-bearing zone, and not the deep aquifer. 

71. The assumptions made for this calculation are independent 
of the mass balance calculations. The amount of selenium 
in the groundwater is based on the vertical and lateral 
distribution of selenium as determined from more than 100 
wells in the vicinity of Kesterson Reservoir. 

72. "Spociation of the mine water selenium by Ward confirmed 
80-95 percent selenate and the remainder as selenite" 
(Kauffman et al. 1984). This water was used in the soil 
column experiments. 

73. Under immobilization, the Reservoir will be maintained with 
clean water. The selenium concentration of this water 
will be well below 200 yg/1. 



5-63 



74. The pond option would result in increased flow rates as 
compared to no action (Draft EIS p. 4D-2 4) ; however, these 
rates would be similar to the rates observed while the 
Reservoir was in operation (Draft EIS p. 4D-26) . 

75. The USER believes that 9 yg/1 selenium is a conservative 
estimate for extracted water because the wells will draw 
uncontaminated water from depth. (See response to comment 
53 for the distribution of soluble selenium with depth. 
See also Table 2-2 which shows results of selenium measure- 
ments in existing water supply wells) . 

76. Significant amounts of selenium are not expected to migrate 
into the shallow aquifer under this plan. However, the 
influx of water may flush soluble selenium from the pore 
water underlying the Reservoir (see response to comment 53 
for the distribution of soluble selenium with depth) . This 
process is further described on p. 4D-28 of the Draft EIS. 

77. The preliminary extraction network was designed to inter- 
cept the underflow due to the regional flow and the applied 
surface water. Extraction wells to the north and west were 
not included for the following reasons: 1) selenium con- 
centrations in Mud Slough have not exceeded EPA's criteria 
for the protection of freshwater aquatic life, 35 pg/l; 2) 
the extraction system will reduce seepage to Mud Slough; 
and 3) the selenium concentration of the recycled water 
will be less than the influent drain water. 

78. A perched zone does not exist in the vicinity of Kesterson 
Reservoir; however, wells drilled in the vicinity of the 
proposed reverse osmosis plant indicate that a shallow 
groundwater zone underlain by thick clays does exist there. 
Data are available to support the statements on p. 4D-30 
(CH2M Hill 1985) . 

79. The principal surface water system components relevant to 
an understanding of the Kesterson Reservoir cleanup are 
provided in Figure 4-16. 

80. Local runoff is not necessarily agricultural runoff. His- 
torically, the majority of the surface water used in the 
vicinity of Kesterson Reservoir was for flooding duck ponds 
and supplying the wildlife refuge. 

Specifying irrigation supply and surface return water 
instead of fresh water may also be appropriate; however, 
data on the sources of this water are unavailable. 

Although agricultural drainwater did not constitute a 
majority of the deliveries until 1981, substantial quan- 
tities of water were delivered between 1978 and 1981. As a 
result, seepage began affecting the groundwater conditions 
in the vicinity of the Reservoir may have begun as early as 
1978. 

5-64 



81. The data by Presser and Barnes (1984 and 1985), Izbicki 

(1984), and Gilliom (1986) would have been reviewed. 
The USER feels that the data presented in the Draft EIS are 
adequate for evaluating the cleanup alternatives. 

82. TDS levels decrease in the summer and fall because irriga- 
tion return water is lower in TDS than the surface and 
groundwater that feed the sloughs in the winter and spring. 

83. The USER agrees with the suggested correction. The correc- 
tion has been included on the errata sheet. 

84. The USER agrees with this comment. 

85. The potential for the oxidation and subsequent migration of 
selenium via surface water in the SLD exists. Water quali- 
ty in the SLD will be monitored to verify that selenium has 
been immobilized. 

86. USER agrees with this assessment. 

87. Please see the response to comment 85. 

88. Please see the response to comment 21. 

89. It was assumed that 80 percent of the oxidized forms of 
selenium would be adsorbed and that 20 percent would be 
available for leaching. An adsorption rate of about 90 
percent was derived from fitting the conceptual model to 
the estimates of selenium mass balance (p. 4D-17) ; however, 
preliminary laboratory speciation work indicated that 
closer to 80 percent of total selenium would be adsorbed. 
A discussion of adsorption is provided on p. 4A-12 of the 
Draft EIS. 

The model calculations are shown in Figure 4-15 and Table 
4-27. When better estimates of selenium adsorption/de- 
sorption are available (from LBL and others) , selenium 
fluxes may be recalculated. 

90. Tolerance thresholds for boron contamination are extremely 
low. The values cited here are those used by Maas (1986). 

91. The Water Management Research Laboratory of the USDA Agri- 
cultural Research Service measured selenium levels in a 
small number of grab samples collected on September 26, 
1984 (Hoffman pers. comm.). At Kesterson Reservoir, three 
samples of cattail and sea purslane contained from 3.4 to 
18 ppm selenium, dry weight. At the Los Eanos Desalination 
Plant, five samples of cattail and bulrush contained from 
8.6 to 119 ppm selenium. Concentrations in below-ground 
plant parts were consistently higher than in above-ground 
parts. In agricultural fields south of Mendota, eight 



5-65 



samples of food and fiber crops contained from 0.12 to 
0.82 ppm selenium. The above data do not alter the results 
of the impact analysis. 

92. The USER agrees with this assessment. Attached and plank- 
tonic algae would tend to absorb selenium present in the 
SLD water. 

93. Herbicide application is no longer part of USBR's proposed 
action, as described in the Final EIS. 

94. Based on research performed in preparing the Draft EIS, the 
USSR believes that even though the selenium concentrations 
from Volta Wildlife Management Area are of interest, adding 
them will not change any major conclusions reached in the 
Draft EIS. 

95. The errata sheet indicates this correction. 

96. At present, the USER is unable to address the Maximum 
Acceptable Toxicant Concentrations (MATC) for any elements 
other than selenium. The USFWS recently recommended 3 ppm 

(dry weight) selenium as a MATC for waterfowl food includ- 
ing aquatic plants, plankton, and adult insects. This 
value was based on USt^WS feeding studies of mallards at the 
Patuxent Wildlife Research Center (Smith pers. comm.). 

97. Biological monitoring to be conducted as part of the FRP 
will determine the rate of reduction of selenium 
concentrations in cattails and the food chain effects of 
cattail consumption. 

98. Further testing has indicated that beryllium and nickel are 
not contaminants of concern at Kesterson Reservoir. The 
detection limit for beryllium is well above the TTLC crite- 
rion for hazardous waste material and is therefore not con- 
sidered further. Four sediment samples from the SLD ex- 
ceeded the proposed designated waste criterion for nickel 
on a dry weight basis. However, none of the samples ex- 
ceeded the criterion on a wet weight basis and nickel was 
therefore not considered further. 

99. Comment acknowledged. The value of 84 mg/kg for the aver- 
age concentration of selenium in SLD sediments is calcu- 
lated from samples taken from the top, middle, and bottom 
of sediment accumulations. There is no significant differ- 
ence between depths. The average therefore represents the 
entire volume of accumulated sediments. 

100. There have been two studies done on selenium levels in 
agricultural crops in the Kesterson Reservoir and SLD 
vicinities. The Hoffman USDA study referenced in the EIS 
has valid selenium data based on analytical procedural 
reviews. Another study has been conducted by the State 

5-66 



Department of Food and Agriculture (Segura et al. 1985) . 
The results of this study are still under review. The 
errata sheet indicates the suggested clarification. 

101. The survey did not sample cattle grazing immediately adja- 
cent to Kesterson Reservoir because during this fall survey 
the Freitas cattle were grazing on lands outside the San 
Joaquin Valley and were unavailable to the study team. 

102. The selenium levels reported by EPA were for drinking water 
supplies. The errata sheet indicates this clarification. 

103. While the selenium levels in the Selected Minerals and Food 
Survey, as cited by Pennington et al. (1984) were reported 
in mg/day, selenium levels were converted to yg/day for the 
sake of consistency. 

104. Clarification of the location of the 14 wells discussed in 
the public health section is reflected on the errata sheet. 

105. Selenium in salt crusts on vegetation is a potential 
exposure pathway. Although there could be some worker 
exposure to these salt crusts, health effects are not 
expected to differ from those discussed for soil excavation 
on p. 4N-29. 



5-67 




DEPARTMENT OF THE ARMY 

SACRAMENTO DISTRICT. CORPS OF ENGINEERS 

650 CAPITOL MALL 

SACRAMENTO. CALIFORNIA 95814 



REPLY TO 
ATTENTION OF 



June 18, 1986 
Regulatory Section 



Susan Hoffman 

Kesterson Program Manager 

U.S. Bureau of Reclamation 

2800 Cottage Way 

Sacramento, California 95825-1898 

Dear Ms. Hoffman: 

We are responding to your request for comments on the Kesterson Program 
Draft EIS. 

One of the off-site mitigation alternatives investigated was acquisition 
of the Burt Crane property (See Page 1-14 and Figure I-l). This property was 
previously identified by the U.S. Fish and Wildlife Service as the mitigation 
lands required for the Corps Merced County Streams, California flood control 
project. 

Acquisition of this property by the USBR would have significant adverse 
Impact on the Merced project which was Included in PL 99-88 as a new 
construction start for FY-86. Statements on Page 1-31 of the DEIS indicate 
the Burt Crane property has been dropped from further consideration as a 
mitigation alternative. However, if the USBR renews its Interest in this 
property, the FEIS and other Kesterson project documents should address the 
impact on the Merced project If this property were acquired by the USBR. 

The Corps of Engineers objects to consideration of the 2,800 acres of 
off-site mitigation lands as part of the Kesterson Program and requests that 
it be deleted. The reason is that the U.S. Fish and Wildlife Service had 
previously recommended (1980) the same area as mitigation for the Merced 
County Streams Project and this was accepted and authorized into law by 
Congress in 1985, PL 99-88. Further, the U.S. Fish and Wildlife Service has 
agreed to purchase these lands to serve both the Merced County Streams Project 
mitigation and the Separate program of the Service known as the "East 
Grasslands Project" of some 35,000 acres in the vicinity of Merced, California 
also authorized by Congress. If the Bureau falls to delete the 2,800 acres 
from their program, all of these interrelated aspects must be fully explained 
in the EIS. 

Sincerely, 




, Art Chainp 
^ Chief, Regulatory Section 

5-68 



Response to Comments of the U. S. Army Corps of Engineers 

1. As indicated on p. 1-31 of the Draft EIS, USER and USFWS 
have eliminated the Burt Crane Ranch from further consid- 
eration as a mitigation wetlands for the Kesterson Program. 
Neither agency plans at this time to renew interest in this 
property for Kesterson Program mitigation. 



5-69 



0' 






V 



\ 



I 22^ ' UNITED STATES ENVIRONMENTAL PROTECTIONAGENCY 

%«<}^<^ REGION IX 

215 Fremont Street 
San Francisco. Ca. 94105 



June 30, 1986 

Mr. David Houston 

Regional Administrator 

U.S. Bureau of Reclamation 

2800 Cottage Way 

Sacramento, California 95825 

Dear Mr. Houston: 

The Environmental Protection Agency (EPA) has reviewed the 
Draft Environmental Impact Statement (DEIS) titled KESTERSON 
PROGRAM, MERCED AND FRESNO COUNTIES, CALIFORNIA. Our specific 
comments on this DEIS are enclosed. We appreciate the information'' 
that has been included in the DEIS and the efforts being undertaker 
to conduct the studies needed to develop an appropriate cleanup 
plan. 

Because of our involvement in the earlier scoping meetings 
and our review of prior technical reports, we recognize the 
difficulty involved in structuring an EIS to meet NEPA require- 
ments while still complying with the time schedules associated 
with the mandated cleanup schedule. Though we concur with the 
basic phased approach set forth in the DEIS, we feel it is 
essential that the final EIS (FEIS) identify specific decision 
points and decision criteria for requiring subsequent cleanup 
actions, if necessary. These decision factors are especially 
critical since many of the environmental uncertainties will not 
be resolved until ongoing studies are completed. We also 
believe this phased approach will, in all likelihood, require 
subsequent NEPA documents to describe the actual cleanup 
actions; the FEIS should describe such a process. 

The lack of specific cleanup details makes it difficult 
to fully assess the adequacy of the plan. However, assuming 
that the additional criteria, decision points, and the NEPA 
process are adequately described in the FEIS, we have rated the 
overall EIS as an EC-2 (Environmental Concern-Insufficient 
Information). Issues of concern which need to be further 
addressed include: 1) impacts to ground water from selenium 
leaching and subsidence, 2) the feasibility of offsite wetland 
mitigation plans, 3) the effectiveness of the Immobilization 
Plan, particularly with regard to wetland fish and wildlife 
resources, 4) herbicide use, and 5) impacts to air quality from 
particulates and herbicide emissions during incineration and 
from hydrogen selenide emissions. 

5-70 



-2- 



In contrast with our overall agreement on the proposed 
cleanup approach, however, we have significant reservations 
about the "Flexible Response Plan" identified in the DEIS. 
Because of the combination of numerous uncertainties inherent 
in this alternative, we have rated it as EO-2 (Environmental 
Objections - Insufficient Information). We have arrived at 
this rating because of the following concerns: 1) the presumption 
that wetland mitigation may not be required under the wet 
option; 2) the conveyance of CVP water through contaminated 
sediments in the San Luis Drain; 3) the potential for selenium 
to leach under the dry option or during dry harvesting; and 4) 
the lack of defined criteria and a timeframe for implementing 
successive stages of cleanup. 

The classification and date of EPA's comments will be 
published in the Federal Register in accordance with our public 
disclosure responsibilities under Section 309 of the Clean Air 
Act. See the attached "Summary of Rating Definitions and 
Follow-up Action" for information on the classification system. 

We appreciate the opportunity to review this DEIS and are 
available to meet with you to discuss our concerns. Please 
send eight copies of the Final Environmental Impact Statement 
to this office at the same time it is officially filed with our 
Washington, D.C. office. For further information, please 
contact Mr. Rick Hoffmann, Federal Activities Branch, at (415) 
974-8191 or FTS 454-8191. 



incerely yours. 





Charles W. Murray, Jr. [^ 
Assistant Regional Adminisi 
for Policy and Managements 



itor 



Enclosure (7 pages) 



5-71 



-1- 



General Conunents 

1. Because of the short time schedule mandated to clean up 
Kesterson Reservoir and the fact that studies are still 
ongoing, a phased approach to the cleanup is presented in 
the DEIS. The FEIS needs to describe how this phased 
approach will be implemented. Of particular concern is 
the lack of criteria which will trigger each subsequent 
level of cleanup. Specific criteria (i.e., a certain 
concentration of selenium leaching into the ground water 
which will trigger ground water extraction) must be 
included in the FEIS. The decision points at which these 
criteria will be evaluated should be identified, as 
well. 

10 2. If a phased approach is used, the FEIS needs to address 
the ongoing public environmental review process. We are 
concerned that the NEPA process will close before the 
data needed to determine the ultimate alternative for 
cleanup is completed. It may be necessary to prepare 
supplemental environmental documentation if. data from 
ongoing studies reveals that impacts or alternatives are 
going to be significantly different than those presented 
in the EIS. 

11 3. More flexibility in combining various alternatives may be 
warranted. For example, in the Offsite Disposal Plan, 
the environmental and economic impacts of dredging and 
hauling all of the contaminated sediments to a Class II 
landfill are analyzed. However, the DEIS does not considerl 
as part of other alternatives, limited excavation of hot 
spots which may alleviate potential ground water contami- 
nation problems. 

Ground Water Comments 



12 



A mixing model of 
volume, performed 
the selenium ion 
aquifer, the atte 
predicted. There 
are not recommend 
selenium when the 
best, a shallow s 
environment, but 
the proper condit 



selenium concentration versus pore 
during our review, indicates that once 
(presumably as selenate) enters the 
nuation rate may not be as rapid as 
fore, the dry option and site cap option 
ed because of the increased mobility of 
reservoir is periodically flooded. At 
oil cap results in a reduced oxygen 
not an oxygen free one. This creates 
ions for selenium leaching. 



13 



In the description of the Flexible Response Plan, it is 
stated that in order to reduce the cost, dry harvesting 
is the preferred method for removing vegetation at Kestersoj 
Reservoir. In this case, the sediments would not be kept 
in an anoxic environment. Based on past monitoring data 
for periods where the ponds have been dried up and then 
refilled, the amount of selenium which may potentially 



5-72 



-2- 



leach from the sediments due to the dry harvesting method 
should be estimated. The DEIS states: "wet harvesting 
would be conducted if it were determined that temporary 
drying would cause serious impacts due to immobilization 
of selenium." If adequate information is not currently 
available to estimate the impacts of drying the ponds, 
when will this data be obtained? At the very least, the 
FEIS should fully describe the criteria upon which the 
decision to utilize dry or wet harvesting will be made. 



14 



3. Figure 4-3 contains a map of Kesterson Reservoir depicting 

the preconstruction thickness of the surficial clayey 

material. The FEIS should discuss mitigation measures to 

alleviate potential selenium transport from those areas 
with a clay thickness of zero to two feet. Of particular 

concern are the two areas where selenium leaching is 
known to occur. 

5^5 4. Several options presented in the DEIS call for pumping 
ground water to augment the surface flow to Kesterson 
Reservoir. The DEIS calls for 3,000 to 13,000 acre feet 
of ground water to be pumped annually. Kesterson Reservoir 
rests on alluvial fill overlying the Tulare Formation. 
The Tulare is a preserved lacustrine deposition system. 
Such a system is subject to subsidence resulting from 
withdrawal of ground water from storage. The use of 
ground water may not be viable if basin subsidence 
occurs. The subsidence potential should be quantified, 
and well siting and pumping schedules identified, in the 
FEIS. 

15 5. Borate is a reasonably conservative ion during ground 
water transport. Continued use of Kesterson Reservoir 
will cause the borate to migrate and be discharged into 
the Salt Slough-San Joaquin River system. This system is 
utilized for irrigation water downbasin from the reservoir. 
Therefore, the impact (if any) on irrigation uses should 
be considered. 

17 6. The DEIS references a State-required ground water monitoring 

plan. The FEIS should present the location of wells, findings 
to date, etc., from this plan. 

Surface Water Comments 

18 1- Under the Flexible Response Plan, San Luis Drain sediments 
would not be removed. This creates the potential for con- 
taminating the CVP water which will be transported to 
Kesterson via the San Luis Drain. In addition to resolu- 
bilization, a significant quantity of solid matter may 
also be resuspended. The FEIS should describe what 
actions will be taken to alleviate this potential source 
of selenium input to Kesterson Reservoir. The amount of 
selenium which may enter Kesterson due to the contaminated 



5-73 



19 



- j- 



San Luis Drain sediments should be included in the FEIS. 
Alternative measures to alleviate this potential selenium 
source were briefly discussed, such as utilizing ground 
water under Kesterson in lieu of CVP water. Additional 
information on the impacts and benefits of using ground 
water should be included in the FEIS, as well. 



2. The FEIS should discuss the basis for the molybdenum ambient 

20 goal of 70 ug/1. Literature data suggest that this level 
may not be acceptable for irrigation supply water. 

Section 404 of the Clean Water Act Comments 

EPA has reviewed the proposed Kesterson Program for compliance 
with the Section 404(b)(1) Guidelines. We have the following 
comments in this regard: 

21 1. Under the 404(b)(1) Guidelines, the only permittable 
alternative is that with the least-damaging impacts to 
the aquatic environment, so long as that alternative does 
not have other significant environmental impacts (40 CFR 
230.10(a)). Therefore, even though the No-Action alter- 
native requires the least discharge of fill into waters 
of the United States, this alternative has proven to have 
significant adverse impacts on the aquatic environment. 
Similarly, other alternatives which involve minimal fill 
may also have the potential for significant adverse impacts 
to the aquatic environment, such as the Flexible Response 
Plan and Immobilization Plan pond option. Uncertainty 
still exists regarding the effectiveness of the wet 
and pond options to immobilize selenium and prevent sig- 
nificant adverse impacts to the aquatic environment. 



22 



It appears that options which involve removal of contaminated] 
vegetation and sediments would have the greatest potential 
for long-term environmental benefits. From the standpoint 
of wetland resource values, the Wetland Restoration/Onsite 
Disposal Plan may be most promising. Creation or enhancement; 
of wetlands in areas that have supported wetlands historically 
has been far more successful than attempts to create 
wetlands in upland areas. 

23 2. The DEIS assumes that mitigation for lost wetland values 
may not be necessary under the Flexible Response Plan wet 
option, if viable wetlands eventually re-establish themselves 
at Kesterson Reservoir. Under the wet option, wetland 
values at Kesterson would continue to be degraded and to 
be of little use to migratory waterfowl. The FEIS should 
evaluate the length of time that wetland values will 
remain degraded under this option before contingency 
actions are taken to implement alternative mitigation 
plans. EPA disagrees with the assumption that wetland 

24 mitigation would not be needed. Accordingly, we believe 
that costs associated with the Flexible Response Plan wet 
option are artificially low. 

5-74 



-4- 



3. For alternatives that 
probability of succes 
creation or enhanceme 
length of time expect 
success should be dis 
cleanup of Kesterson 
loss of wetland value 
The FEIS should also 
that may be required, 
wetland/waterfowl val 



do propose wetland mitigation, the 
s for the various wetland restoration, 
nt plans should be evaluated. The 
ed to achieve a given level of 
cussed. A phased approach to the 
should not result in an indefinite 
s and associated waterfowl habitat, 
address possible remedial actions 

if attempts to create or restore 
ues are unsuccessful. 



The DEIS (pg. 3-29) estimates that revegetation of mitigation 
sites under the Immobilization Plan will cost nearly $6 
million dollars. The FEIS should provide a cost breakdown of 
this revegetation effort, as well as a range of costs 
associated with less intensive efforts. A range of 
revegetation costs should be included in other alternative 
plans as well. 



Portions of 
appear to b 
EPA and the 
FEIS should 
within Corp 
presently b 
Water Act. 
should be r 
existing we 
mitigation 



some of the proposed offsite mitigation areas 
e "waters of the United States" as defined by 

U.S. Army Corps of Engineers (Corps). The 

identify how much of these sites are now 
s jurisdiction, including areas that may 
e farmed under Section 404(f) of the Clean 

Credit for wetland creation or ehancement 
educed, where appropriate, to reflect any 
tland acreage that is included as part of any 
plans . 



Due to the uncertainty over the effectiveness of the Flexi- 
ble Response and Immobilization Plans, additional options 
embodied in other alternatives may be required. These two 
alternatives, as presented in the DEIS, may be overly 
optimistic in terms of cost and success. The FEIS should 
provide more information regarding the probability of 
success for all of the alternatives presented. The following 
are particular concerns regarding the Flexible Response Plan 
and Immobilization Plan: 



32 



a. The pathways for selenium re-entering the biosphere 
are not well defined (pg. 3-24). 

b. The potential bioavailability of selenium from plants 
growing in the ponds is not known. 

c. Other pathways are uncertain (i.e., plankton, fish, etc.) 

The DEIS indicates ( pg . 4H-15) that aquatic invertebrates 
may sequester high concentrations of selenium and may 
constitute a significant source of this contaminant 
through food-chain pathways. The DEIS does not evaluate 
remedial options for dealing with these potential sources 



5-75 



-5- 



32 



33 



34 



of selenium bioavailability, but rather focuses on plant 
and water pathways. The FEIS should evaluate potential 
impacts and remedial actions to deal with these potential 
sources . 

8. The DEIS states that the Corps believes that the discharge 
of fill into Kesterson is exempted from 404 regulation 
because it is considered to be a waste treatment facility. 
The FEIS should reflect that EPA disagrees strongly with 
this opinion. EPA does not believe that evaporation 
constitutes treatment or that the Kesterson National 
Wildlife Refuge is a waste treatment facility. We do not 
object to a 404(r) exemption, so long as the Kesterson 
Program complies fully with EPA's 404(b)(1) Guidelines. 

Herbicide Comments 

In our previous comments on this project we requested detailed 
information on the use of herbicides. The DEIS provides little 
information in this regard. The DEIS states (pg. 4B-19) 
"herbicides may be used to facilitate harvesting .. .and. . .also 
may be used after harvesting." The FEIS should present a more 
detailed plan for the use of herbicides, including types, 
acreage, amounts, frequency of application and short and 
long-term impacts. 



All herbicid 
Department o 
uses must be 
DEIS indicat 
It should be 
Environmenta 
direct appli 
address the 
application 



es used must be registered by EPA and the California 
f Food and Agriculture for the specific use(s). Ai: 

in accordance with all label requirements. The 
es that the preferred herbicide is glyphosate. 

noted that Roundup (Monsanto) carries the following 
1 Hazard statement regarding glyphosate: "Avoid 
cation to any body of water." The FEIS should 
issue of dry versus wet conditions during herbicide 
and the type of herbicide appropriate. 



35 



36 



Finally, because the regulatory status of chemicals is constant] 
changing, we recommend a review of the current status of any 
herbicides used, prior to each application season. 

Air Quality Comments 

1. Because the DEIS does project possible violations of the 
particulate standard during construction (cleanup) 
activities, the FEIS should include a commitment to 
implement the mitigation measures proposed in the DEIS. 

2. The DEIS does not adequately address the following concerns; 
the FEIS should do so: 



37 



a. Emissions of herbicides from incineration of vegetation 
under the Flexible Response Plan. 



5-76 



-6- 



b. Emissions of and exposure to hydrogen selenide when the 
ponds are anaerobic. 

Calculations and a description of calculation techniques 
used in evaluating these emissions should be included in 
the FEIS. 

The following specific changes should be made in the FEIS: 

a. Page 4B-11 - Other selenium compounds should be considered. 

b. Page 4B-12 - Table 4-10 should consider emissions of 
herbicides during application and incineration. 

c. Page 4B-16 - Particulate emssion control on the incinerator 
should be included as a mitigation measure (Flexible Response 
Plan) . 

d. Page 48-19 - "Combustion tests" should include herbicide 
emissions. 

e. Page 48-20 - Stack (not "stock") gas temperature should 
be much less that the temperature in the combustion zone 
(1,500°F). 



5-77 



SU»lAR3f OP RATING DEFINITIONS AND FOUO/MJ? ACTION* 
E^wlrormental Impact of the Action 






LP— Lack of CblectlT ?. ^ 

The EPA review ha8~not Identified any potential environmental Inpacta requiring |B 
substantive changes to the proposal. The review may have disclosed opportunities ^^ 
foe application of mitigation measures that could be accotnplished with no more than 
minor rf^ang«s to the proposal. 



w 



EC— Bivirorngntal Concerns 

The EPA review has IdentiTled envlrorroental ImMKrts that should be avoided in order ^_ 

to fully protect the environment. Corrective meeisures may require changes to the H| 

preferred alternative or application of mitigation measures that can reduce the ^^ 

envlrorroental impact. E3>A would like to work with the lead agency to reduce these 

ImpeK^s. ^M 

ED — Environmental Objections 

The EPA review has identified significant envlrorroental impacts that must be avoided 

in order to provide adequate protection for the environment. Corrective measures may ^| 

require substantial changes to the preferred alternative or consideration of seme 

other project edtemative (including the no action adtemative or a new alternative). 

EPA Intends to work with the lead agency to reduce these impacts. H 

EU — Envirorroentally Unsatisfactory 

The EPA review has identified adverse enviromental inpacts that au:« of sufficient 

magnitude that they are unsatisfactory from the standpoint of public headth or H 

welfaune or environmental quality. EPA intends to work with the lead agency to reduce • 

these iirpacts. If the potential unsatisfactory impacts are not corrected at the final 

EIS stage, this proposal will be recommended for referral to the CEO. 



Adequacy of the Impact Statement 



P 



Category 1— Adequate ■ 

EPA Believes the draft EIS adequately sets forth the envlrorroental inpactCs) of r 
the preferred alternative and those of the alternatives reasonably availadble to the 

project or action. No further analysis or data collection is necessary, but the m 

reviewer may suggest the addition of clarifying language or information. I 

Category 2—- Insufficient Infonnatlon 

The draft EIS does not cxjntain suffTclent information for EPA to fully assess 

envlrorroental impacts that should be avoided in order to fully protect the environment, 

or the EPA reviewer has identified new reasonably available alternatives that are 

within the spectnin of alternatives analyzed in the draft EIS, which could reduce 

the enviroonental litpacts of the action. The identified additional information, data, 

analyses, or discussion should be included in the final EIS. 

Category 3 — Inadequate 

EPA does not believe that the draft EIS adequately assesses potentially significant 
envlrorroental impacts of the action, or the EPA reviewer has identified new, 
reasonably availad^le alternatives that are outside of the spectrum of edtematives 
analyzed in the draft EIS, which should be analyzed in order to reduce the 
potentially significant enviroonental inpacts. EPA believes that the identified 
additional Information, data, analyses, or discussions aire of su<A a magnitude that 
they should have full public review at a draft stage. EPA does not believe that the 
draft EIS is adequate for the purposes of the NEPA auid/or Section 309 review, and 
thus should be formally revised aind made available f<x" public connent in a si43plemental 
or revised draft EIS. On the basis of the potential significimt Inpacts involved, 
this proposal could be a candidate fnr npfer-ral to the CEQ. 

5-78 
*Fttxn: EPA Manual 1640 troiicy ana rtocedures for the Review of 
Federal Actions Inpacting the Eiivironraent 



Response to Comments of the U. S. Environmental 

Protection Agency 

1. The Final EIS contains a description of USBR's proposed 
action which is more detailed than the description con- 
tained in the Draft EIS. The Final EIS description of the 
proposed action specifies decision points and criteria to 
be used in the phased approach. 

2. The USER expresses no opinion, at this time, as to whether 
implementation of the proposed phased approach will require 
future NEPA documentation. USER will use existing NEPA 
procedures (Council on Environmental Quality NEPA regula- 
tions, and Department of the Interior and USER NEPA proce- 
dures) to decide whether future Kesterson Program actions 
are sufficiently addressed in the existing EIS. For exam- 
ple, USER will prepare a Supplemental EIS if the existing 
EIS becomes seriously outdated and is no longer considered 
accurate for use in decisionmaking, or if the program has 
changed to such an extent that impacts will be significant- 
ly different (USER NEPA Handbook, Section 4-19). 

3. Please see responses to the detailed comments v;hich follow. 

4. USER believes that the Final EIS has sufficiently addressed 
the four concerns listed by EPA, and that the "EO-2" rating 
need no longer apply. 

5. Mitigation alternatives for the FRP under consideration are 
described in the proposed action description presented in 
this Final EIS. 

6. In response to this concern, conveyance of CVP water 
through contaminated SLD sediments is not part of USER'S 
proposed action, as described in this Final EIS. 

7. Under the proposed action. Ponds 6 and 8-12 will be main- 
tained as dry areas, with seasonal wetlands. Dry harvest- 
ing is no longer proposed; instead, vegetation will be 
disced following the completion of research assuring that 
discing will not incrase selenium mobility. Leaching of 
selenium in the northern ponds is not expected to adversely 
affect beneficial uses of groundwater or surface water. 
The groundwater monitoring program will verify this assump- 
tion; corrective action will be taken if groundwater moni- 
toring indicates selenium threshold levels are being 
exceeded. 

8. This Final EIS contains a detailed description of the 
proposed action including specific decision points and 
criteria for each phase. 

9. This Final EIS contains a description of the USER'S 
proposed action which is more detailed than the description 

5-79 



contained in the Draft EIS. The Final EIS proposed action 
specifies decision points and criteria to evaluate the 
effectiveness of the phased approach. 

10. Please see the response to comment 2. Existing NEPA guid- 
ance will be used to determine whether supplemental Kester- 
son Program NEPA documentation will be prepared. The Final 
EIS for the Kesterson Program will be issued prior to 
collection of future monitoring data to determine whether 
the FRP is successful. The USER agrees that it may be 
necessary to prepare supplemental NEPA documentation if 
monitoring data reveal that impacts or alternatives will be 
significantly different than those presented in the EIS. 

11. The intent of formulating alternatives based on combina- 
tions of components is to allow flexibility in choosing a 
preferred approach. The Onsite Disposal Plan, as described 
in the Final EIS proposed action, provides for excavation 
of "hot spots." 

12. Please see response to comment 7. 

13. The Final EIS description of the proposed action contains 
more detail on vegetation management, monitoring, and deci- 
sion criteria than was provided in the Draft EIS. As part 
of the proposed action's FRP, the ponds that have histor- 
ically remained wet will not be dried or harvested, thereby 
reducing risks of selenium leaching. 

14. Groundwater monitoring and corrective action programs are 
described in further detail in the proposed action descrip- 
tion in this Final EIS. 

15. Data are not available to adequately evaluate the potential 
for subsidence at Kesterson Reservoir in response to 
groundwater extraction. However, LBL is conducting a 
hydrogeologic investigation at the site. Data from this 
investigation, in combination with drawdown and water yield 
data from wells the USER has installed to supply water to 
the Reservoir, will be sufficient to evaluate the potential 
for subsidence at the site. 

Preliminary indications are that the shallow aquifer can 
sustain yields in excess of 5,000 acre-feet per year with- 
out significantly impacting water levels in the area. 
Therefore, potential for subsidence would be greatest in 
the immediate vicinity of the extraction wells. 

16. Since delivery of drainwater to Kesterson Reservoir has 
ceased, loading of boron into the system has been sub- 
stantially reduced. High levels of boron in the ground- 
water beneath Kesterson Reservoir are the result of past 
discharge of drainwater. The rate of regional groundwater 
flow into the Salt Slough-San Joaquin River system is slow 

5-80 



enough that increases in boron levels in that system are 
expected to be negligible. 

17. The Final EIS proposed action describes the groundwater 
monitoring program. The program is being developed in 
detail as part of the CPMP, which is expected to be imple- 
mented in March 1987. Specific findings and results will 
be made public when available. 

18. In response to this concern, the SLD will not be used to 
convey CVP water to Kesterson Reservoir under the proposed 
action. Water will be kept in the drain, however, to 
maintain its structure and to keep sediments covered, 
thereby immobilizing contaminants. 

19. The plan for using groundwater is discussed in the Final 
EIS description of the proposed action. Impacts of ground- 
water use were described in the Draft EIS (pp. 4E-17 to 
4E-18) . 

20. The source of the 70 yg/1 criteria for molybdenum, as 
listed in Table 4-22, is the EPA as cited by Marshack 1985 
(see References section) . These criteria are listed as the 
"Estimated Permissible Ambient Goal for (human) Health 
Effects." More recently, EPA listed an AADI (Adjusted 
Acceptable Daily Intake) to protect human health from 
molybdenum of 100 pg/l as reported in the Federal Register , 
Vol. 50, No. 219, dated November 13, 1985. Also reported 
in this Federal Register are the federal health advisory 
levels for children and adults over a 10-day exposure 
period, which are 270 and 950 yg/l, respectively. 

The recommended maximum concentration of molybdenum in 
irrigation waters for continued use on all soils, based on 
animal toxicities from forage bioaccumulation of this 
element, is reported to be 10 pg/1 (National Academy of 
Sciences 1972) . 

21. Assuming the applicability of the Section 404(b)(1) guide- 
lines (see response to comment 33 below) , USER has asses- 
sed the relative impacts of the alternative actions on 
aquatic environments. Of course, the guidelines will not 
apply to management actions that do not involve discharge 
of dredged or fill materials. Also, it should be noted 
that the Section 404(b) (1) guidelines would not be relevant 
to the Kesterson Program if the COE ' s determination that it 
has no Section 404 jurisdiction over Kesterson Reservoir is 
correct. Filling activities associated with each plan, as 
described in Chapter 2 of this Final EIS, are as follows. 
Under both the Flexible Response Plan and the Immobiliza- 
tion Plan the filling up of 230 acres of seasonal wetlands 
in the northern ponds with clean fill from an offsite 
source may be required; filling will occur if progress 
toward achieving water quality and biota cleanup goals is 

5-81 



not being achieved. Under the Onsite Disposal Plan, about 
30 acres of Pond 3 will be filled with contaminated sedi- 
ments and vegetation, and about 10 acres adjacent to the 
landfill will be filled with clean fill from an offsite 
source to create a buffer. Filling of seasonal wetlands 
may also be necessary under this plan if selenium remaining 
in residual soils following excavation causes water quality 
or biological contamination. 

Impacts, risks, and mitigation measures associated with the 
above filling activities are described in Chapter 3 of this 
Final EIS. 

22. As noted in the Draft EIS, those options calling for re- 
moval of contaminated vegetation and sediments create the 
least risk to biota. The USER agrees that, in principal, 
it is easier to create or enhance historic wetlands than to 
create wetlands in upland areas. The Onsite Disposal Plan 
as currently proposed, however, does not call for re- 
creation of wetlands at Kesterson Reservoir via additional 
water application, because of concerns regarding potential 
residual contamination following sediment excavation. 

23. USER agrees that the wetland habitat values of Kesterson 
Reservoir would be reduced, compared to precontamination 
habitat values, during the 5 years when the FRP is being 
evaluated. 

24. The proposed action description in this Final EIS discusses 
short-term and long-term mitigation alternatives being 
considered. 

25. The Gallo and Wolf sen properties being considered for off- 
site wetland development were recommended by USFWS as 
suitable for wildlife habitat development. USER is unaware 
of any factors that would make these parcels unsuitable for 
wetland development. 

26. If offsite wetlands were purchased and developed, it could 
take several years to achieve full habitat values. Alter- 
natively, if mitigation involved providing a water supply 
to existing wetlands, habitat values would be immediately 
realized. 

27. If creation or restoration of offsite or onsite wetlands 
were unsuccessful, an alternative mitigation approach would 
be to supply water to existing wetlands. See the proposed 
action description in this Final EIS. 

28. If offsite wetlands are purchased and developed, USER now 
believes that revegetation will not be essential, thereby 
substantially reducing the costs of this mitigation alter- 
native. 



5-82 



29. No portions of the specific parcels being considered for 
offsite mitigation are, to USBR's knowledge, considered 
"waters of the United States" which would receive discharge 
of dredged or fill material if developed as wetlands. If 
offsite mitigation wetlands are developed, existing habitat 
values would be taken into account. 

30. USER agrees, as stated in the Draft EIS, that uncertainty 
exists regarding the effectiveness of the FRP and Immobili- 
zation Plan. This uncertainty will be resolved through the 
phased approach embodied in USBR's proposed action. The 
Draft EIS and Final EIS present the most current available 
data on the probability of success of all the alternatives. 
See discussion of FRP risks in Chapter 3 of this Final EIS. 

31. See discussion of FRP risks in Chapter 3 of this Final EIS. 

32. Selenium levels in invertebrates are currently being moni- 
tored in a 1-acre test pond and in Kesterson Reservoir to 
determine the effect of substituting selenium-free water. 
Future monitoring to be conducted under the proposed action 
will determine whether invertebrates are being contami- 
nated, and the extent to which food chain effects occur. 

33. The EPA's disagreement with the COE ' s jurisdictional deter- 
mination is noted. USER plans to follow Section 404 (r) 
procedures to avoid dispute over the jurisdictional issue. 

34. Because of concerns regarding herbicide application, the 
proposed action as described in this Final EIS no longer 
calls for use of herbicides as a vegetation control method. 

35. Please see the response to comment 34. 

36. The Final EIS contains a list of USER environmental commit- 
ments . 

37. Neither herbicide application nor vegetation incineration 
is currently part of USBR's proposed action. 

38. Emissions of hydrogen selenide were not estimated in the 
Draft EIS because of its high reactivity in the atmosphere. 
Volatilization emissions were calculated assuming all 
selenium emissions were dimethyl selenide due to its more 
long-range transport impacts. The literature was not clear 
in defining the difference between anaerobic and aerobic 
emissions of selenium. More data are being collected now 
in a study by LBL, but this information is not yet avail- 
able. 

39. The forms of selenium evaluated in the analysis focused on 
elemental selenium and dimethyl selenide, as presented on 
p. 4B-11 of the Draft EIS. Selenium can volatilize as 
hydrogen selenide or volatile methylated forms. Hydrogen 

5-83 



selenide is very reactive and rapidly oxidizes to elemental 
selenium. Dimethyl selenide is the predominant volatile 
form of the expected methylated selenium compounds. Di- 
methyl diselenide is another form of methylated selenide, 
but it is expected to make up only a minor fraction of the 
total methylated selenide emission (Doran and Alexander 
1976) . 

40. Please see the response to comment 37. 

41. The user's proposed action does not involve incineration of 
vegetation. 

42. Even though vegetation incineration is not currently in- 
cluded in the proposed action, the USER agrees with the 
suggested changes. The errata sheet reflects that "stack" 
gas temperature should be much less than the assumed 
temperature of 1,500°F in the combustion zone, and that 
additional modeling would be required to reflect the 
specific incinerator design parameters. 



5-84 



SACRAMENTO ADDRESS 

n STATE CAPITOL 

SACRAMENTO CA 9S814 
(9161445 7380 

DiSTRCT OFFICES 

D 7949 D WREN AVENUE 
GILROY. CA 95020 
(408I 648-1461 

D 545 J STREET. SUITE 14 
LOS BANOS CA 93635 
(209) 826-6100 

n 140 CENTRAL 

SALINAS CA 93901 
(408)422-4344 







RUSTY AREIAS 

ASSEMBLYMAN, TWENTY-FIFTH DISTRICT 

CHAIR. COMMITTEE ON GOVERNMENTAL 

EFFICIENCY AND COST CONTROL 

VICE CHAIR. RURAL CAUCUS 



COMMITTEES 
AGRICULTURE 
TRANSPORTATION 
WATER. PARKS AND 

WILDLIFE 
POIICY RESEARCH 

COIvr^lSSION OF 
THECALIFORNIAS 



STATEMENT OF ASSEMBLYMAN RUSTY AREIAS REGARDING THE KESTERSON 

RESERVOIR CLEAN UP PLAN 

JUNE 17, 1986 



As Assemblyman of the 25th Assembly District, an agriculturalist 

and lifetime resident of Merced County, I am extremely concerned 

with drainage disposal in the San Joaquin Valley, the impact 

of current drainage practices on the health and environment 

of area residents, and the economic effects of clean up proposals, 



I feel it is the responsibility of the Bureau to see that a > 
successful clean up plan is developed and implemented 
immediately. It is also the Bureau's responsibility to 
protect the health and environment of the people in Merced ^ 
and neighboring counties. The potential impacts or consequences 
of the plugging of the San Luis Drain and long-term drainage 
solution greatly concern me. The federal government must 
ensure that all socioeconomic impacts are mitigated. In 
addition, the Bureau must closely monitor all water entering 
our wildlife areas, sloughs and rivers to prevent additional 
Kestersons and maintain a productive system of farming in the 
valley. 5-85 



I realize fully that costs associated with these efforts are 
enormous. As you know, cleaning up Kesterson will cost a 
great deal of money as will any long term drainage solution. 
However, the federal govermnent in bringing the San Luis Drain 
to the Valley with the promise of a solution for agricultural 
drainage must now live with the consequences of its actions 
by correcting an intollerable situation. 



In conclusion, I wish to point out that farmers and wildlife 
interests alike seek a solution to the drainage problem in the 
Valley. While the debate between these two groups continues 
over the most promising solutions, agreement on responsibility 
is clear — it is the responsibility of the federal government 
to take action to correct contamination of Kesterson and to 
seek whatever appropriations are necessary to remedy 
agricultural drainage problems in the Valley. The Bureau 

must recognize its responsibilities. It must acknowledge the 
jurisdiction of state agencies and comply with their mandates. 
It must acquire whatever federal funding is necessary to 
correct the drainage problem. I urge that these costs not 
be passed along to districts contracting with the federal 
government. Finally, the Bureau must act promptly to ensure 
the health of area residents. 

Thank you very much for the opportunity to present this statement 
on Assemblyman Areias' behalf. 

5-86 



Response to Comments of Assemblyman Rusty Areias 

1. The USER shares Assemblyman Areias' concern for the health 
and environment of the people of Merced County and through- 
out the United States. The proposed action described in 
the Final EIS has been designed to best implement the 
user's responsibilities for the Kesterson Reservoir clean- 
up. 

2. The impacts of plugging the collector drains, including 
socioeconomic impacts, are assessed in the USSR's EIS for 
the Contingency Program for the Westlands Water District 
Drainage Disposal Project (1986) and the Westlands Water 
District EIR for the Elimination of Drainage Water Flow 
into the SLD (1985 and 1986) . The long-term drainage prob- 
lems in the San Joaquin Valley are being addressed by the 
various agencies participating in the San Joaquin Valley 
Drainage Program (SJVDP) ; such issues are beyond the scope 
of this EIS. 

3. The USER shares the Assemblyman's concerns for protecting 
our natural environment and ensuring the continued via- 
bility of San Joaquin Valley agriculture. The USER, along 
with the USFWS , are studying various aspects of these 
issues. However, issues of water quality for wildlife 
areas beyond Kesterson Reservoir and issues of San Joaquin 
Valley agriculture are beyond the scope of this EIS. 

4. The USER recognizes its lead responsibility for the clean- 
up of Kesterson Reservoir. The USER is also working with 
other agencxes as part of the SJVDP to help formulate a 
long-term solution to agricultural drainage problems; the 
USER is currently investigating funding alternatives for 
solutions to these problems. 

5. The proposed action has been formulated with the objective 
of protecting public health, and includes a public health 
monitoring program. 



5-87 



•" of California 



The Resources Agencl 



<leinorandu 



rn 



Secretary for Resources 
1416 Ninth Street 
Sacramento, CA 95814 

Attn: Projects Coordinator 



Date 



June 27, 1986 



Deportmenf of Fish ond Game 



SCH 860505151 - Kesterson Program 
(EIS), Merced/Fresno Counties 



- Environmental Impact Statement 



GENERAL COMMENTS 

The transmittal letter in the subject EIS states that the U.S. 
Bureau of Reclamation's proposed action is a phased approach 
calling for an initial action and followed by successive actions 
if the initial action fails. Each successive action is more 
complex and costly than the last. As the EIS states, there is a 
significant risk of recontamination of fish and wildlife habitat, 
Therefore, we are unable to agree that a phased approach is the 
most valid solution from an environmental standpoint for the 
cleanup of Kesterson Reservoir and the San Luis Drain. 



USER 

Resp 

wetl 

rela 

sign 

few 

(Cha 

para 

usin 

alte 

6). 

The 

seve 

to i 

this 

rela 

perc 

main 

prov 

be a 

inve 

coul 



proposes 
onse - Wet 
and vegeta 
tively low 
ificant ri 
seasons, a 
pter 4-F, 
graphs 5 a 
g the San 
rnative at 



to impl 
Option 
tion at 
cost . " 
sks of 
nd that 
page 21 
nd 6). 
Luis Dr 
least 



ement as an 
". The int 

the earlie 

USBR cone 

recontamina 

levels of 
; paragraph 

Continued 
ain would a 
initially ( 



initial action a "Flexible 
ent of this option is "to restore 
st possible opportunity and at 
ludes that there could be 
tion, particularly for the first 
contamination could be undesirable 

2; Chapter 4-H, page 27, 
contamination of fish and wildlife 
Iso probably occur with this 
Chapter 4-H, page 29, paragraph 



n 



next pro 
ral seas 
mplement 
plan wo 
tively i 
eive at 
taining 
ided by 
n att rac 
r tebrate 
d al low 



iposed action 
ons shows thi 
an "Immobil 
uld be to ma 
mmobile and 
least two ma 
anaerobic co 
luxuriant pi 
tion to wate 
s; and 2) fa 
recontami na t 



to b 
e fir 
izati 
intai 
nonto 
jor p 
ndi ti 
ant g 
r f owl 
i lure 
ion o 



e im 
St a 
on P 
n se 
xic 
robl 
ons 
rowt 

and 

to 
f th 



plemented, if monitoring for 
ction is unsuccessful, would be 
Ian - Pond Option". The goal of 
lenium and other contaminants in 
anaerobic conditions. We 
ems with this action: 1) 
requires organic detritus 
h. Flourishing plant life would 
their food chain which includes 
maintain anaerobic conditions 
e food chain and present a high 



5-88 



id 



-2- 

risk to the wildlife that would be attracted by the plant life. 
(Chapter 4-F, page 24, paragraph 1, Chapter 4-H, page 32, 
paragraph 1). The prospect of several more years of contamination 
of wildlife and their habitat is a risk we cannot endorse. For 
example, there is no method for determining the impacts on 
migratory waterfowl. 

A major weakness of these two actions is the reliance on hazing to 
keep birds away during initial seasons when the risk of 
recontamination is highest. Hazing, according to information from 
USFWS personnel conducting the present hazing at Kesterson, has 
proven to be ineffective in keeping away certain species of birds 
and has not deterred the nesting instinct of certain species. 

The information in the EIS transmittal letter discussed above 
leads the DFG to conclude that neither the first option nor the 
second option would be satisfactory from an environmental 
standpoint because of the risk of continuing harmful effects on 
fish and wildlife. However, in the event USER does initiate 
either Option 1 or Option 2, we have several suggestions and some 
observations: 

1. Planning and research should continue for all three choices 
listed in the phased approach. 

2. Adequate monitoring is one of our major concerns. The EIS 
should contain more information on a monitoring plan. In 
addition, the mechanisms for determinig the phased approach is 
working or not should be described in some detail. 

SPECIFIC COMMENTS 

1. Chapter 3, page 14, paragraphs 5 and 6 

It appears that monitoring programs will be closely tied to 
current studies being funded under the San Joaquin Valley 
Drainage Program (SJVDP). Adequate funding for the SJVDP has 
been a problem to date. Funding shortfalls could add to the 
length of time it will take to obtain information needed for 
satisfactorily monitoring the cleanup of Kesterson. 

2. Chapter 3, page 22, paragraph 2 

A project responsibility should be full funding for 
operational costs of wetland mitigation sites. The USFWS 
staff managing San Luis and Kesterson National Wildlife Refuge 
may need to be supplemented as well. 



5-89 



-3- 

Chapter 3, page 36 - Disposal of Wetland 

Putting contaminated groundwater on wetlands, even through 
diluted, will over a period of time, put the same pounds of 
contaminants on the wetland. Another method of disposal of 
contaminated groundwater should be considered. 

Chapter 3, page 43 

A brine pond located near the Mendota Wildlife Area with 
varying water depths in winter and spring may need a 
bird-hazing program on a 24-hour basis. 



10 



Chapter 5, page 3, paragraph 2 

Statement: "The SJVDP is addressing long-term . . . 
suggest you add after this: "as well as short-term 



We 



We will be most willing to discuss our comments with USBR staff 
Our contact for this project is Larry Puckett, Environmental 
Services Supervisor. His phone number is 916-978-4975. 





v; 



Jack C. Parnell 
Director 



U 



5-90 



Response to Comments of the California Department of 

Fish and Game 

1. The USER agrees that a significant risk of contamination of 
fish and wildlife exists under the FRP , as described in 
several places in the Draft EIS. See discussion of FRP 
risks in Chapter 3 of this Final EIS. 

2. The USER agrees that the specific risks identified by the 
Department of Fish and Game (DFG) exist with the FRP and 
Immobilization Plan, as indicated in the Draft EIS. Moni- 
toring of impacts on biota, including migratory waterfowl, 
will determine the seriousness of these risks. See discus- 
sion of FRP risks in Chapter 3 of this Final EIS. 

3. The USER agrees that hazing is only partially effective in 
keeping bird species from using Kesterson Reservoir. 
Whether species that cannot be hazed will be at risk under 
the FRP will be determined through biological monitoring. 

4. The proposed action described in this Final EIS includes 
ongoing research and decision criteria for all three 
phases. This approach will enable the USER to effectively 
monitor the progress of the selected approach and modify 
planning decisions if necessary. 

5. This Final EIS contains a description of the USER'S pro- 
posed action which is more detailed than the description 
contained in the EIS Draft. The Final EIS proposed action 
specifies the monitoring program as well as decision points 
and criteria to evaluate the effectiveness of the phased 
approach. 

6. The USER has requested $11.5 million to fund the SJVDP 
during fiscal year 1987. Of that amount, $5.5 million is 
to be earmarked for support of the Kesterson Program. If 
funding for the SJVDP is reduced, cutbacks would be 
expected to impact both programs. The funding reductions 
experienced by the two programs would not be expected to be 
proportionate because SJVDP activities are not subject to 
the time constraints faced by the Kesterson Program. 

7. The ultimate determination of which entity (or entities) 
will bear the cost of cleanup and postclosure maintenance 
of Kesterson Reservoir lands and/or the development or 
operation of new waterfowl management areas is beyond the 
scope of this EIS. The Department of the Interior will, 
however, charge any component of such costs as are properly 
borne by CVP project users under existing Reclamation laws 
to those entities. If it is subsequently determined that 
the allocation of the repayment obligation for the costs of 
the Kesterson closure and cleanup actions may result in 
physical environmental impacts, the USER will prepare 



5-91 



supplemental environmental documentation addressing these 
effects. 

8. Of the estimated 7,900 kg of selenium delivered to Kester- 
son Reservoir via the SLD, less than 200 kg has migrated 
into the groundwater (see Draft EIS Table 4-3) . The major- 
ity of the selenium remains in the soil and detritus under- 
lying the Reservoir. Under the Onsite Disposal Plan, the 
selenium in the soils and detritus will be placed in an 
onsite disposal facility. The amount of selenium delivered 
to the mitigated wetlands via extracted groundwater will, 
therefore, be less than 200 kg. After infiltrating through 
the surface sediments at the mitigated site, considerably 
less of this amount will be available for groundwater 
transport. 

9. Use of a brine pond near the Mendota Wildlife Refuge is not 
part of the USBR's proposed action, as described in this 
Final EIS. 

10. USER agrees that the SJVDP is addressing both long-term and 
short-term solutions to valley-wide drainwater problems. 



5-92 



STATE Of CALIFORNIA— HEALTH AND WELFARE AGENCY 



DEPARTMENT OF HEALTH SERVICES 



2151 BERKELEY WAY 
BERKELEY, CA 94704 

(415)540-2669 



GEORGE DEUKMEJIAN, Govvmor 




June 27, 1986 



Ms. Susan E. Hoffman 

Program Manager 

US Bureau of Reclamation 

2800 Cottage Way 

Sacramento, California 95825 

Dear Ms. Hoffman: 

Thank you for the opportunity to comment on the Kesterson Program draft 
environmental impact statement dated April, 1986. We appreciate that the 
authors have incorporated suggestions from the Department of Health Services 
in the chapter on Public Health (4N) . It appears to incorporate the 
information presently available. 

The following comments serve to reiterate and emphasize some of the points 
already in the draft document: 

1. p. 4K-1 The Asian population needs better definition. The 
estimate of between 7,000 and 24,000 is inadequate to assess the 
population at risk. 

2. p . 4M The South East Asian population needs to be mentioned. 

3. p. 4N-5-6 The fish and wildlife consumpation patterns need to be 
elaborated. 

p. 4N-10 As is correctly stated, there are many unknowns. Further 
information is needed, which can be developed as the cleanup 
proceeds . 

If you have information or question you would like to discuss, please contact 
me . 

Sincerely yours. 



Lynn Goldman, M.D. 
Medical Epidemiologist 
Epidemiological Studies and 
Surveillance Section 



5-93 



Response to Comments of the California 
Department of Health Services 

The USER appreciates the Department of Health Services' 
(DHS's) continuing input and cooperation. As noted by the 
commenter, the Draft EIS includes a discussion of the Asian 
population and recognizes that further information is 
needed. Consequently, an ethnographic survey of potential- 
ly affected populations has been completed. 



5-94 



STATE O." CALIFORNIA— HEAITH AND WELFARE AGENCY 



GEORGE DEUKMEJIAN. Gowmor 



DEPARTMENT OF HEALTH SERVICES 

2131 BERKELEY WAY 
BERKELEY. CA 947CU 

(415) 540-3063 




June 18, 1986 



Susan Hoffman 
Kesterson Program Manager 
U.S. Bureau of Reclamation 
2800 Cottage Way 
Sacramento, CA 95825-1898 

Dear Ms. Hoffman: 

We are pleased to submit our comments on the Draft Environmental Impact 
Statement, Kesterson Program, dated April 1986, with specific reference to 
the section on public health. 

In general, it would be helpful if the headings and subheadings of the 
section were numbered. Specific comments are enclosed. 

Sincerely, 



A 



".-■5 



Raymond R. Neutra, M.D. , M.F.H. 
Chief, Epidemiological Surveillance 
and Studies Section 



5-95 



Comments on 

Draft Environmental Impact Statement 

Kesterson Program 

April 1986 

(With Specific Reference to the Section on Public Health) 



Prepared by 

Community Toxicology Unit 

and 

Epidemiological Studies and Surveillance Section 

Office of Environmental Health Hazards Assessment 

Department of Health Services 

2151 Berkeley Way 

Berkeley, CA 94704 



5-96 



i 



Affected Environment 

1. Pg. 4N-3, Subsection on Selenium and Human Health 

The discussion involves selenium intake through different routes (e.g., 
dietary and inhalation), levels of intake, concentrations in different 
media (e.g., food and air), and human health effects reported in the 
literature. It would be useful to point out that the forms of selenium 
to which humans can be exposed to can vary, that each form has 
different toxic properties, and that there is a lack of speciation data 
on selenium in Kesterson and surrounding areas to which the populations 
potentially at risk may be exposed. 

2. Pg. 4N-3, p. 4 

It is not clear which of the 1985 EPA documents was cited. 

3. Pg. 4N-4, p. 2 

"Safe levels of selenium intake have been shown to prevent Keshan 
disease (cardiomyopathy) in humans (Rose, 1983), coronary heart 
disease, cancer, and the toxicity of other elements such as arsenic, 
cadmium, mercury, and certain pesticides (EPA, 1980a)." 

This statement is incorrect. 



5-97 



Safe levels of selenium Intake have been shown to prevent Keshan 
disease in humans, but have not been shown to prevent coronary heart 
disease or cancer. Results in long-term follow-up studies relating 
selenium levels to the risk of chronic disease such as coronary heart 
disease are conflicting (Am J . Epi. 122:276-282. 1985). Although 
studies have suggested 1) a lower cardiovascular mortality in higher 
selenium areas compared with low selenium areas (Proceedings of the 
Nordic Symposium "Mineral Elements '80," Helsinki, 501-9, 1981). 2) a 
low serum selenium concentration associated with an increased risk of 
cardiovascular disease (Lancet 2:175-179, 1982), and 3) an inverse 
correlation between mortalities from cancer of several body sites and 
the apparent dietary selenium intake and blood selenium, the results 
are only suggestive and support the hypothesis that selenium has 
protective effects against these cancers and cardiovascular disease. 
They did not show a preventive effect, however, because these are only 
statistical associations and a cause-and-effect relationship has not 
been shown. 

In discussing human health, the EIS also cited the EPA document as 
indicating that selenium intake prevents the toxicity of arsenic, 
cadmium, mercury, and other chemicals. It did not clarify that these 
effects were cited by EPA as being demonstrated in experimental 
animals. 



5-98 



4. Pg. 4N-4, p. 5 

The EIS cited the report of Yang et al. as showing an association 
between toxic levels of selenium in humans and abnormal hair and nail 
growth, skin lesions, tooth decay, and central nervous system 
disorders. It did not point out that the association with tooth decay 
is only a possibility. 

The Yang report stated that "since there was some fluorosis reported in 
this area, it could not be decided whether the tooth damage was caused 
by the fluoride or selenium alone or by a combination of the two." 

5. Pg. 4N-6, p. 3 (Same as for Pg. 4N-10, p. 6) 

"Duck tissues collected from the Kesterson Reservoir in 1985 had a 
maximum selenium level of 2.3 ppm, wet weight." 

6. Pg. 4N-8, p. 1 

The review committee found no evidence to indicate any adverse health 
effects . The negative finding is not limited to "acute toxic effect." 

7. Pg. 4N-8. p. 3 

The original citation for the average 1968 population levels of 220 
/xg/l in the nation for serum selenium was not given. 



5-99 



10 



11 



12 



13 



Impacts of Alternatives 

8. Pg. 4N-9, p. 5, line 3 

It Is not clear which of the 1985 EPA documents was cited. 

9. Pg. 4N-15, p. 2 

What Is the health significance of workers' dermal contact with 
contaminated water, sediments, and soils when they are doing job- 
related tasks on site? 

What is the health significance of an average selenium level of 55 ppm 
in the top 1 inch of reservoir sediments? 

10. Pg. 4N-17, p. 5 

The EIS indicated that two individuals in the Kesterson Reservoir study 
area had higher selenium levels in their hair (when compared to other 
individuals in the study) , but failed to identify that these two 
individuals used a shampoo that contained selenium. Absorption is not 
expected (See pg. 4N-4, p. 5) unless the skin is abraded. 

11. Pg. 4N-21, p. 5 

The EIS indicated that the preferred herbicide is glyphosate and that 
herbicide combustion products have not been identified. 



5-100 



According to information provided by the herbicide manufacturer, tests 
showed that when glyphosate is burned in the air, 72% of the material 
is changed to one of four decomposition products, while the remaining 
28% becomes carbon ash. Of the decomposition material, 25% is water, 
4% is acetonitrile (CHj CN) , and 43% comes off as carbon dioxide (COj) 

and phosphorous pentoxlde (PjOj). A human hazard assessment performed 

by the manufacturer showed that based on the comparison of maximum 
possible exposure level of phosphorous pentoxlde (and considering 
conversion to phosphoric acid, HjPO^) and acetonitrile to the threshold 

limit value, the thermal decomposition products of glyphosate pose no 
hazard to Individuals who may be exposed to the smoke or gasses formed 
as a result of the burning of glyphosate -treated vegetation. An 
application rate of 5 quarts/acre was assumed in the assessment. 

12. Pg. 4N-30, p. 4 



15 



The EIS indicated that restricted migration of affected groundwater 
would reduce the potential for public exposure to contaminants in the 
groundwater over time. It was not explained how water migration would 
be restricted. 



5-101 



2. 



3. 



Response to Comments of 
the California Department of Health Services 

The suggested change is editorial in nature and does not 
change the essential conclusions of the Draft EIS. The 
USER and its consultants have attempted to organize the 
Kesterson Program EIS in a manner that is both informative 
and easy to follow. It is recognized that other editorial 
approaches could have also accomplished these goals. 

The USER generally agrees with these observations. Other 
discussions within the document indicate that there are a 
variety of pathways for selenium exposure as well as a 
variety of forms of selenium to which human populations may 
be exposed. 

The confusion is the result of a typographical error. The 
correct reference (EPA 1984) is reflected in the errata 
sheet. 



4. The commenter's references indicate that a clarification 
regarding the potential benefits of safe levels of selenium 
is warranted. The errata sheet reflects such clarifica- 
tion. 

5. The USER appreciates this clarification of Yang's report 
which states that tooth decay has only a possible assoc- 
iation with excess selenium levels. 

6. The USER agrees that clarification would be helpful. The 
comment also applies to p. 4N-16. The errata sheet re- 
flects the clarification. 



The USER agrees with the DHS ' s correction, 
sheet indicates the suggested change. 



The errata 



9. 



The DOI Report which cited the 1968 population serum selen- 
ium levels did not provide the original citation. 

The correct reference (EPA 1985b) is reflected in the 
errata sheet. 



10. Very little information is available regarding dermal 
absorption of the selenium species present at Kesterson 
Reservoir (see p. 4N-4) . The dermal information available 
is for industrial settings and is generally pertinent to 
organic forms of selenium, such as selenous oxychloride. 
Selenate, the most prevalent species of selenium at Kester- 
son Reservoir, has an average dermal LD50 of about 3 mg/kg 
based on subcutaneous applications to dogs and rats. The 
calculated dermal LD50 for Kesterson Reservoir surface 
soils/sediments is 53,000 mg/kg. Subcutaneous exposure is 
not expected to occur unless a worker's skin is abraded. 



5-102 



The water that will be found in the Reservoir following 
closure is expected to contain low levels of selenium; 
however, if monitoring indicates selenium is becoming 
mobilized in the surface waters, the above discussion is 
pertinent. 

In general, because of the paucity of information available 
on the potential health effects of dermal exposure to the 
species of selenium found at Kesterson Reservoir, the 
health significance of workers' dermal contact is unknown. 
Workers at Kesterson Reservoir will be monitored as part of 
the public health monitoring program included in the 
proposed action. 

11. The evaluations presented in the Draft EIS for health 
impacts of soil/sediment excavation used an average soils 
content of 5 ppm, which is the approximate level expected 
for exposure scenarios under either the Onsite Disposal 
Plan or the Offsite Disposal Plan. Dermal contact with 
Kesterson Reservoir sediments is discussed above under 
response to comment 10. 

12. Although the Merced County Health Department report indi- 
cated the individuals who had higher selenium levels in 
their hair did use dandruff shampoo, subsequent information 
given to the U. S. Food and Drug Administration (FDA) 
indicated that one of these individuals did not use a 
dandruff shampoo. Therefore, according to Dr. R. Jacobs of 
the FDA, the significance of the finding of higher selenium 
in at least one individual is still unknown. 

13. The USER agrees with this assessment as discussed above in 
the response to comment 10. 

14. The USER appreciates the DHS ' s input on this issue. Incin- 
eration of vegetation to which herbicides have been applied 
is not part of the proposed action. 

15. The offsite migration of selenium would be restricted by a 
line of extraction wells (see Draft EIS p. 4D-29) . 



5-103 



il 



Sat* c( Cjlifornia — TrM H*sourc*i >Ay«nCY Date:_^ 

I OFFICE OF HISTORIC PRESERVATION 
DEPARTMENT OF PARKS AND RECREATION Project 

P.O. BoK 2390 
k Sicram«nto , CA 9581 1 
(916)445.8006 



n April 1986 \ ff 

No.: BUR 860321A ^ 



TITLE- CLEANUP OF SAN LUIS DRAIN/KESTERSON RESERVOIR 

The item cited above was received in this office on 2''-March 1986 

Thank you for consulting us pursuant to 36 CFR 800. 

We concur in your determination that this undertaking: 

'nErdoes not involve National Register or eligible properties. 
D will not affect National Register or eligible properties. 

The provisions of 36 CFR 800.7 apply if previously unidentified National Register or eligible 
resources are discovered during construction. 

Contact Nicholas Del Cioppo of 0^^ staff if you have any questions. 




Kathryn Gualtieri' 

State Historic Preservation Officer 



5-104 



Response to Comments of 
the State Office of Historic Preservation 

The USBR appreciates the Office of Historic Preservation's 
review. 



5-105 



Resources Building 

1416 Ninth Street 

95814 

(916) 445-5656 
TDD (916) 324-0804 

California Conservaiicn Corps 
Department of Boating and Waterways 
Oepanment of Conservation 
Depanment of Fish and Game 
Depa-lment of Forestry 
Department of Parks and Recreation 
Oepanment of Water Resources 



GEORGE DEUKMEJIAN 

GOVERNOR OF 

CALIFORNIA 




THE RESOURCES AGENCY OF CftOFORNrA 

SACRAMENTO, CALIFORNtA 



Ms. Susan Hoffman 
Bureau of Reclamation 
2800 Cottage Way 
Sacramento, CA 95825 

Dear Ms. Hoffman: 



June 30, 1986 



Air Resources Board 
California Coastal Commission 
California Tahoe Conservancy 
California Waste Management 

Board 
Colorado River Board 
Energy Resources Conservation 

And Development Commission 
San Francisco Bay Conservation 

and Development Commission 
Stale Coastal Conservancy 
^tate Lands Division 
fState Reclamation Board 
(state Water Resources Control 

Board 
Regional Water Quality 

Control Boards 



The State has reviewed the draft EIS on the Kesterson Program, 
Merced and Fresno Counties, submitted through the Office of 
Planning and Research. Review was coordinated with the Regional 
Water Board and the Departments of Conservation, Fish and Game, 
Parks and Recreation, V.'ater Resources, Food and Agriculture, Health 
Services, and Transportation. 

Attached are comments received from the Department of Fish and Game. 

The Department of Transportation comments that if the plan selected 
for cleanup requires hauling the contaminated material off site via 
State routes, the proponents should check with the Caltrans Permits 
Office on the legal requirements of this. The Permits Office may be 
reached by calling (916) 445-3303. 

The Department of Parks and Recreation comments that the San Luis 
Island Project, a valley grassland preserve managed by the Department 
(identified as Grasslands State Park in the report), is adjacent to 
the proposed wetlands in the "dry" option of the Flexible Response 
Alternative. Further analysis is needed of the Impacts on San Luis 
Island, especially concerning groundwater supply and quality. Questions 
should be directed to Roger Wlllmarth at (916) 324-6419. 

We understand that the Regional Water Board and the Office of Historic 
Preservation will respond directly to you on this matter. 



Attachment 



Sincerely-^', 

r-^ /Gordon F. Snow^ Ph.D 

"^Z /Assistant Secretary for Resources 



cc: Office of Planning and Research 
1400 Tenth Street 
Sacramento, CA 958l4 
(SCH 86050515) 

5-106 



Response to Comments of the Resources Agency of Californi a 

1. The proposed action described in the Final EIS does not 
include the hauling of contaminated material offsite. If 
the plan is modified at any time to include such hauling, 
the Caltrans Permits Office will be consulted. 

2. Water supply options for potential offsite mitigation 
wetlands are currently being investigated. They include 
use of CVP water and use of local well water. 



5-107 



STATE OF CALIFORNIA 



GEORGE DEUKMEJIAN, Governor 



CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD- 
CENTRAL VALLEY REGION 



SAN JOAQUIN WATERSHED BRANCH OFFICE: 
3614 EAST ASHLAN AVENUE 
FRESNO, CALIFORNIA 93726 
PHONE; (2091445 5116 



26 June 1986 



Ms. Susan Hoffman 

Kesterson Program Manager 

U. S. Department of the Interior 

Bureau of Reclamation 

2800 Cottage Way 

Sacramento, CA 95825-1898 



COMMENTS ON KESTERSON PROGRAM DEIS MP 750123.4 

Our staff has developed comments on the Kesterson Program DEIS. They 
are attached for your review. 



If you have any questions, call Sargeant Green of our staff at 
(209) 445-5116. 




4^c 



HARLOW 
Supervising Engineer 

SJGrhmm 

Attachment 

cc: Mr. Jerry Johns, Bay Delta Program, State Water Resources Control 

Board, Sacramento 
Mr. Dennis Westcot, California Regional Water Quality Control 

Board, Sacramento 
Ms. Peggy Osborn, Office of Planning and Research, Sacramento 



: 



5-108 



Memorandum 



CALIFORNIA REGIONAL WATER QUALITY CONTROL BOARD • CENTRAL VALLEY REGION 

3614E.Ashlan SAN JOAQUIN WATERSHED BRANCH Telephone. (209) 445-51 16 



Fresno, CA 93726-6905 



State Lease Line: 421-5116 



TO: Loren J. HarlovJ-^^WT' 
Supervising Engineer 



FROM: 



Sargeant J. Green 
Senior Land and 
Water Use Analyst 



DATE: 26 June 1986 



SIGNATURE: 




^2=^ 



SUBJECT: uSDI - BUREAU OF RECLAMATION KESTERSON PROGRAM, DRAFT EIS COMMENTS, 
KESTERSON RESERVOIR, MERCED COUNTY 



The USDI Bureau of Reclamation is circulating the subject DEIS for a program 
to bring Kesterson Reservoir into compliance with State Board's V.'ater Quality 
Order 85-1 (WQ 85-1). This memo will review the DEIS in general and for the 
aspects our agency is responsible for. 

The DEIS has numerous alternate plans for meeting the goal of satisfying WQ 85-L 
There is also a no action alternative. The preliminary selected alternative 
is what the report writers call a "flexible response plan". This plan is 
basically a first stage cleanup that proposes a certain amount of action, then 
an evaluation fo whether it has worked. If it hasn't worked, you step up to 
the next alternate and implement it, and so on. 

The Bureau has done an admirable job in developing a planning document for 
cleanup of Kesterson Reservoir. The process, upon implementation, may meet 
the intent of WQ 85-1, however, their are several procedural and technical 
issues that need to be addressed prior to implementation of a selected 
alternative. Those items should be reviewed in the DEIS and include the 
following. 

1. The SWRCB in WQ 85-1 declared the contents of the site a "functional" 
hazardous waste and has asked the Bureau to file under the Toxic Pits Act 
of 1984. The application and fees are to be transmitted to our office. 
There is no discussion of this activity in the EIR (see attached letter). 

2. If the site contains "hazardous" waste, it is also subject to the land 
disposal regulations in Subchapter 15 that apply to hazardous waste sites. 
If the Bureau were to apply to DHS-TSCD for a variance and hence become 
exempt from our hazardous waste regulations and the Toxic Pits Act, the 
waste could possibly be a "designated" waste and subject to the Subchapter 
15 rules regarding that type of waste. There is no discussion regarding 
this possibility. 

If the material at the site under the various alternatives becomes a 
nonhazardous or inert waste, the site would still be subject to a post- 
closure care permit and water quality monitoring program. There is no 
mention in the DEIS of any Board regulation or monitoring program necessary 
for us to determine ongoing protection of water quality. 



b-109 



USDI - BUREAU OF RECLAf^ATION 
KESTERSON PROGRAM, DRAFT EIS 
COmENTS, KESTERSON RESERVOIR, 
MERCED COUNTY 



26 June 1986 



In general, the proposed alternatives lack specific evaluation criteria 
or processes to determine whether the alternative goals are being met. 
A Board-ordered monitoring program would be designed to provide information 
on compliance with a closure/post closure plan permit, but we need the 
Bureau to make application for a specific alternative before we construct 
such a monitoring plan. Therefore, they need an empirical evaluation 
method on the probability of the alternative disposal options to meet 
permit conditions and environmental goals. This should be a part of the 
DEIS. 



discussed. 

constructed 

and prevent 

It does 
mate plans. 

interceptors 

San Luis 
peration or 

in the 
t it could 



The ongoing operation of portions of the San Luis Drain is not 
The canal is largely located in areas of perched water and was 
with "weep" valves in the bottom to relieve hydraulic pressure 
liner failure. The DEIS does not address this incoming water, 
not address its quantity, quality or impact on any of the alte 
In addition, the Bureau of Reclamation has operated subsurface 
and other allied subsurface drainage features connected to the 
Drain in the past. The DEIS does not address the impacts of o 
nonoperation of these allied features. Will ground water rise 
vicinity of these facilities and cause saturation to the exten 
cause ponding and waterfowl impacts during nonoperation? 

1 6. The DEIS would benefit from having WQ 85-1 as an appendix. 

Summary : 

The document as presently drafted presents plans that may comply with the 
intent of WQ 85-1, but lacks a discussion of the institutional and regulatory 
compliance requirements of the various alternatives. I recommend the Bureau 
evaluate these items in selecting an alternative for implementation. 



SJG: hmm 
Attachment 



5-110 



m 



STATE Of CALirOH'J!A ^^ «_.„^— __^ 

STATE WATER RESOURCES CONTROL BOARD 

TAUL n po'.dcrijON building 

001 P STRtei 

f O cox 100 

SACHArUNTO. CALIFORNIA 9b301 



GtCnCE OEUKMfJI AN. Co»»/no»- 



(916) 322-0202 




JUN I 8 1986 



Certified Mail 



Mr. David G. Houston 
Regional Director 
Mid-Pacific Regional Office 
Bureau of Reclanation 
U. S. Department of Interior 
2800 Cottage Way 
Sacramento, CA 95825 

Dear Mr. Houston: 

REQUIREMENTS OF THE TOXIC PITS CLEANUP ACT (TPCA) 

I am writing to notify you that the Bureau of Reclamation must either 
comply with the requirements of the TPCA or provide the State Water Resources 
Control Board (State Board) with evidence that Kesterson Reservoir is not 
covered by this law. The TPCA applies to surface impound.-iients which are 
defined as: 

(w) "Surface impoundiiient" or "impoundment" means a waste management 
unit or part of a waste management unit which is a natural topographic 
depression, artificial excavation, or diked area fonr.ed primarily of 
earthen materials, although it may be lined with artificial materials, 
which is designed to hold an accumulation of liquid hazardous wastes or 
hazardous wastes containing free liquids, including, but not limited to, 
holding, storage, settling, or aeration pits, evaporation ponds, 
percolation ponds, other ponds, and lagoons. Surface impoundment does 
not include a landfill, a land farm, a pile, emergency containment dike, 
tank, or an injection well. 

The State Board has determined that Kesterson Reservoir stores hazardous waste, 
as defined in section 25117 of Chapter 6.5 (Health and Safety Code): 

25117. "Hazardous waste" means a waste, or combination of wastes, 
which because of its quantity, concentration, or physical, chemical, or 
infectious characteristics may either: 

(a) Cause, or significantly contribute to an increase in mortality 
or an increase in serious irreversible, or incapacitating reversible, 

il Iness. 

(b) Pose a substantial present or potential hazard tt) human health 
or envircn.^ent when improperly treated, stored, transported, or disposed 
of, or otherwise managed. 



5-111 



Mr. Dovid G. Houston 



■2- 



The TPCA requires surface impoundment owners to pay an annual fee for State 
Board and Regional Water Quality Control Board TPCA implementation. 
Regulations adopted by the State Board set the initial filing fee at $1,500 
for the first surface impoundment at a facility and $160 for each additional 
surface impound.nent. On April 17, 1986, the State Board adopted the annual 
fee for Fiscal Year 1986-87 of $3,000 for the first surface impoundment at a 
facility and $300 for each additional surface impoundment. Both the initial 
fee and the Fiscal Year 1986-87 annual fee are due 60 days from receipt of 
this letter. 

This letter is the official notice of fees due as required by section 25208.3(c) 
of the Health and Safety Code. If your fee is not paid within 60 days after 
receipt of this notice, a penalty of 1 percent per day, up to 100 percent of 
the original fee, will be assessed. A fee submittal/exemption application form 
and a copy of the TPCA are enclosed. 

Please submit the fee and transniittal form to the California Regional Water 
Quality Control Board, Central Valley Region. For any questions on 
this letter, please contact Terry Brazell of the State Board's Division of 
Water Quality at 322-0202. 



Sincerely, 



OriBiDal SiEUOii Byi 



W. Don Maughan 
Chairman 

Enclosures (2) 



cc: Mr. William H. Crocks 

Executive Officer 

California Regional Water 
Quality Control Board, 
Central Valley Region 

3201 S Street 

Sacramento, CA 95815 



bcc: Central Valley Regional Board, Fresno Office 
TBRAZELL:cajulian:REF: DWQ-C: A-08. 09 



P 

m 



5-112 



m 



Response to Comments of the California Regional Water 
Quality Control Board, Central Valley Region 

1. The purpose of NEPA is to require informed consideration, 
with public involvement, of the environmental effects of a 
proposed major federal action and reasonable alternatives 
to that action. The Draft EIS for the Kesterson Program 
has been prepared to meet this basic requirement. Regard- 
less of the regulatory classification of the contaminated 
materials to be handled at Kesterson Reservoir, the DOI 
intends to manage these materials with due regard to any 
environmental or public health risk posed and in accordance 
with all applicable federal, state, and local laws. Also 
see response to comment 2 below. 

2. In the Draft EIS, the USER made the assumption that the 
material in Kesterson Reservoir would be classified as a 
"designated" waste. The analysis of impacts was then based 
on that assumption. The USER is submitting a waste classi- 
fication package to the DHS and requesting a classification 
of the material in the Reservoir. 

3. The Final EIS more fully describes the proposed action, 
including the monitoring program and decision criteria. 
This description will be further amplified in the CPMP 
which will be submitted to the SWRCB and the Regional Water 
Quality Control Board (RWQCE) by December 1, 1986. Impacts 
of the proposed action are described in detail in the Draft 
EIS and summarized in this Final EIS. 

4. The SLD does not have a specific use as part of the pro- 
posed action. Water will be added to the SLD to maintain 
its structure and to keep sediments covered. Weep holes 
may at tim.es add water to the SLD or remove v;ater from it. 
Previous monitoring along the SLD has shown no contam- 
ination of adjacent shallow groundwater. 

5. The expected impacts of plugging the collector drains are 
described in USBR's Draft EIS for the Contingency Program 
for the WWD Drainage Disposal Program (1986) . 

6. The suggested change is editorial in nature and would not 
change the essential conclusions of the Draft EIS. The 
relevant requirements of WQ 85-1 are summarized within the 
Draft EIS. Much of the information in WQ 85-1 is not 
specifically related to the Kesterson Reservoir cleanup 
program, therefore, the document was not included as an 
appendix. 

7. Those institutional and regulatory compliance requirements 
which most closely relate to the NEPA process under which 
the Kesterson Program EIS was prepared are discussed m the 
Draft EIS in Chapter 6, Consultation and Coordination. The 
USER intends to develop its CPMP in satisfaction of all 
applicable federal, state, and local requirements. 

5-113 



STATE OF CALIFORNIA 



GEORGE OEUKMEJIAN. Governor 



STATE WATER RESOURCES CONTROL BOARD 

PAUL R BONOERSOM BUILDING 

901 P STREET 

P O BOX 100 

SACRAMENTO. CALIFORNIA 95801 

916/324-1253 




Ms. Susan Hoffman 
U. S. Bureau of Reclamation 
2800 Cottage Way 
Sacramento. CA 95825-1898 

Dear Ms. Hoffman: 

KESTERSON RESERVOIR 

Thank you for the opportunity to comment on the Kesterson Reservoir Draft 
Environmental Impact Statement (DEIS). As you are aware, the State Water 
Resources Control Board (State Board) is responsible for the review of the 
final cleanup plan to be submitted on December 1, 1986. Therefore, it is not 
appropriate for me to express approval of any of the proposed options at this 
time. However, I feel the following comments should be brought to your 
attention. 



1. The DEIS discusses the issue of waste classification. A designated waste 
classification should be based on the narrative description given in 
Section 2522, Subchapter 15, Chapter 3. Title 23 of the California 
Administrative Code. This comment should not be construed as State Board 
approval of the conclusions drawn regarding waste classification in the 
DEIS. 

2. The DEIS states that under the Wet Flex Plan there is a continued risk of 
contamination of Kesterson Reservoir vegetation and wildlife. Methods to 
mitigate this impact should be more thoroughly explored. 

3. According to the phased cleanup approach, it may be necessary to change to 
another plan if pollutants are not adequately contained. A formal 
mechanism should be adopted to evaluate the monitoring data and recommend 



5-114 



Ms . Susan Hoffman 



■2- 



I implementation of an alternate plan. The same comment applies regarding the 
necessity to provide off -site wetland habitat to mitigate project impacts. 

I hope these comments are useful to you as you prepare the final Kesterson 
Reservoir EIS. 



Sincerely, 




Walter G. Pettit 

Deputy Executive Director 

cc: California Regional Water Quality 

Control Board, Central Valley Region 
3201 S Street 
Sacramento, CA 95816 



5-115 



Response to Cominents of the State Water 
Resources Control Board 

1. The USER agrees that Section 2522 of Subchapter 15 presents 
criteria for classification of wastes as designated wastes. 
The USER is following the procedures specified under state 
law for determining proper classification. 

2. As described in the Final EIS, the USER'S proposed action 
for the FRP includes a nuisance abatement program to mini- 
mize risks of vegetation and wildlife contamination during 
the initial 5 years of this plan. 

3. The process for evaluating monitoring data and recommending 
implementation of an alternative plan is described in the 
proposed action description contained in the Final EIS. 



1 



5-116 



i^Uu Jnanaaer - Kyiiu Kylerk 



L/iiu of C/usiine 

682 if nlrJ ^oenue 

9.0. ^c 306 

Juiline, (^au/owrua 95322 



wShone 

h09f,S 5 1^-61,71 



June 27, 1986 



Susan Hoffman, MP-405 

Program Manager 

United States Bureau of Reclamation 

Mid Pacific Regional Office 

2800 Cottage Way 

Sacramento, Ca. 95825-1898 

Re: Draft E.I.S. for Kesterson Cleanup Program 

Dear Ms. Hoffman: 

I have reviewed the above-mentioned document, and the response 
thereto of the Merced County Health Department dated June 26, 1986, 
attached hereto. I am in full agreement with the comments of Dr. 
Richard D. Welch, Merced County Health Officer, and Jeff Palsgaard, 
M.S., Director, Merced County Division of Environmental Health, and 
approve and adopt same as though set forth in full. 

Sincerely, 




Earl Wearin 

Acting City Manager 



Attachment 



5-117 




DEPARTMENT OF HEALTH 

DIVISION OF ENVIRONMENTAL HE.\LTH 
210 E. J5TH ST^ P.O. BOX 471 
MERCED. CAUFORNIA 9534 1 
12091 385-7391 



Susan Hoffman MP-405 
Program Manager 
U.S. Bureau of Reclamation 
Mid Pacific Regional Office 
2800 Cottage way 
Sacramento, CA 95825-1898 



June 26, 1986 



Dear Ms. Hoffman: 

The Merced County Health Department, Division of Environmental 
Health has reviewed the draft E.I.S. for the Kesterson Cleanup Program. 
All of our comments are based on the premise that Kesterson Reservoir is 
part of the Kesterson National Wildlife Refuge and should be returned 
to a safe wintering and feeding area for waterfowl in the Pacific Flyway. 

To accomplish this we feel the onsite disposal plan should be 
implemented as soon as the State Water Resources Control Board and Central 
Valley Regional Board have approved the cleanup plan. Advantages in 
implementing the onsite plan are as follows: 

1. The onsite plan has the least number of potentially 
significant unavoidable adverse impacts. 

2. The site is restored to a safe wildlife area. 

3. One time removal of vegetation. 

4. Little risk of contamination of new wetland vegetation. 

5. No significant leaking to groundwater since reservoir 
sediments have been removed. 

6. Hazing noise is eliminated. 

7. Reduces the risk of foraging. 
Disadvantages of using the phased approach include: 

1. Continuation of hazing noise. 

2. The existing problems of contaminated vegetation, wildlife, 
groundwater and poaching may continue. 



5-118 

AN AFFIRMATIVE ACTION/EQUAL OPPORTUNITi' EMPLOYER 



3. There is no guarantee the phased approach will work. 
The existing problems of contaminated vegetation, 
wildlife, groundwater and poaching may continue. 

4. Continuation of monitoring people working at the 
reservoir and living adjacent to the reservoir. 

General Comments : 

Page 3-16: 

No mention is made of what criteria will be used with the phased 

approach to implement the different plans. For example, at what 
point has the Wet Flex Plan failed? Do increased levels of 
selenium found in groundwater indicatcthe Wet Flex Plan has 

failed? This is a significant area that has not been addressed 
in the E.I.S. 

Page 3-30: 

Since no specified use of the San Luis Drain (SLD) is being proposed 
south of Bass Avenue, the drain should be plugged at Bass Avenue 
to assure that no subsurface drainage water is drained into the SLD. 

Page 4A-21: 

Soil from the SLD would be dryed at the reservoir and disposed in 
Pond #8. It is recommended that all SLD sediments be taken to an 
appropriate landfill site for disposal and not be disposed at 
Kesterson Reservoir. Storage of soil at the reservoir should be 
limited to what is currently at the reservoir. 



Paq 

6 

Pag 



e 4B-16: 

Air monitoring for particulates and selenium compounds should be 
included in the mitigation measures. 

e 4D-1: 
All plans include programs for groundwater monitoring. Pesticides 
and sodium should be included in the monitoring program (EDB and 
D-D have been found in the surface water in significant amounts). 
Sodium has not been monitored and should be included in any ground- 
water monitoring program. 

Page 4D-3: 

The statement is made that "DWR concluded that the water was not 
used for any beneficial uses...". The Regional Water Quality 
Control Board has identified beneficial uses of the groundwater as 
irrigation and stock watering. 

Page 4E-2: 

The text states that "Malathion has been detected in one out of 
47 samples and phorate in three out of 47 samples." The text 
deletes the significant findings that 38 of 47 samples had 
detectable levels of D-D mixture and 17 of 47 samples had detectable 
levels of EDB. These levels of pesticides are significant and 
should be included in a groundwater monitoring program. 



5-119 



10 



11 



Page 4N-12: 

At what point would adjacent residents be temporarily relocated 
and who would be relocated? 

The State Water Resources Control Board cleanup and abatement should 
be included and referenced to the fact that the State and Regional Water 
Board must approve the plans before implementation. 

If you have any questions, please contact our office at (209) 385-7391, 



Very truly vyo;jrs. 
RfcKard^Twelch, M 





h Officer 



Jeff Palsgaard, M.S., Director 
Division of Environmental Health 



RDW/JP/jrd 

cc: Sarge Green 

Regional Water Quality 

Control Board 
3614 E. Ashlan 
Fresno, CA 93726 



5-120 



Response to Comments from the City of Gustine Incorporating 
Comments of the Merced County Department of Health 

1. An objective of USBR's proposed action is to return 
Kesterson Reservoir to a safe waterfowl habitat. 

2. The phased approach allows for selection of the Onsite 
Disposal Plan if the FRP is not capable of meeting selenium 
reduction goals. See discussion of FRP risks in Chapter 3 
of this Final EIS. 

3. The Final EIS contains a description of the USBR's proposed 
action which is more detailed than the description con- 
tained in the Draft EIS. The Final EIS specifies the 
monitoring program, decision points, and criteria to be 
used for evaluating the effectiveness of each phase of the 
proposed action. 

4. An engineered flow control structure has been installed at 
Bass Avenue to ensure that no SLD flow is allowed north 
beyond that point. 

5. As described in this Final EIS, SLD sediments will not be 
excavated or disposed of under any phase of the proposed 
action. 

6. This Final EIS specifies the air quality monitoring program 
under the proposed action. 

7. The groundwater monitoring program will not contain pro- 
visions for monitoring pesticides, but sodium monitoring is 
included. Pesticides are not being monitored because 
previous sampling for pesticides and herbicides in 
Kesterson Reservoir and SLD surface waters indicated that 
concentrations were (with the exception of one sample) 
below the level of detection (Presser and Barnes 1985) . 

8. The statement in the Draft EIS pertained to known existing 
uses of groundwater in the Kesterson Reservoir vicinity, 
and was not intended to reference present and potential 
beneficial uses identified by the RWQCB for regulatory 
purposes . 

9. The groundwater monitoring program will not contain pro- 
visions for monitoring pesticides. Pesticides are not 
being monitored because previous sampling for pesticides 
and herbicides in Kesterson Reservoir and SLD surface 
waters indicated that concentrations were (with the excep- 
tion of one sample) below the level of detection (Presser 
and Barnes 1985) . 

10. The USER has determined that relocation of residents will 
not be necessary as other public health and air quality 
mitigation measures will adequately ensure public health. 

5-121 



11 



The relevant requirements of WQ 85-1 are summarized within 
tne Draft EIS. Much of the information in WQ 85-1 is not 
specifically related to the Kesterson Reservoir Cleanup 
Program. Therefore, the entire document was not included 
The CPMP will be submitted to the RWQCB at the same ?ime i^ 
IS submitted to the SWRCB. 



m 
m 



5-122 




[LiiDetoir 



CONTRA COSTA WATER DISTRICT 

1331 Concord Avenue • P. O. Box H20 
Concord, California 94524 
(415) 674-8000 or 439-9169 



DIRECTORS 
CRAIG Z RANOALU presiOEKT 
BETTE BOATMUN, vice pnESlOE^^r 
DONALD P. FREITAS 
RONALD E. BUTLER 
DANIEL L. PELLEGRINI 



JOHN E. DeVITO. GENERAL manager 

JOHN S. GREGG, asst general manager 



June 26, 1986 



Ms. Susan E. Hoffman 
Program Manager 
U.S. Bureau of Reclamation 
2800 Cottage Way 
Sacramento, CA 95825-1898 

Subject: Environmental Impact Statement - Kesterson Program 

Dear Ms. Hoffman: 

The Contra Costa Water District has reviewed the Kesterson 
Program Draft EIS and offers the following comments. 

The District's primary concern is the protection of the San 
Francisco Bay Delta system. Any action taken should insure 
that all contaminants are contained and that the potential 
for entry into groundwaters or surface waters that interact 
with the San Joaquin River and/or the San Francisco Bay-Delta 
is virtually eliminated. 

The report should address all potential contaminants. The 
EIS stresses the selenium problem and demonstrates that 
Kesterson contains high concentrations of many trace elements 
as well as total dissolved solids. The report doesn't state 
at what level other contaminants i.e. nonvolatile total 
organic carbon compounds, total organic halogens, etc., are 
present at Kesterson. Such information is necessary to 
assess the potential impacts of the proposed alternative 
projects. 

It is important that any monitoring program track all 
potential contaminants and that you have in place a response 
plan should monitoring detect water degradation. It is 



5-123 



Ms. Susan E. Hoffman 
June 26, 1986 
Page 2 



therefore suggested that the report include a discussion of 
the proposed response plan in the event of containment 
failure. The report should assess any potential impacts of 
the response plan and demonstrate its viability. 

Thank you for the opportunity to review and comment on the 
Kesterson Program Draft EIS. 

Very truly yours. 



Edward W. Cummings 
Special Projects Engineer 



EWC/dvw 

cc: John Gregg 

CCIQW - c/o John Nejedly 



5-124 



Response to Comments of the Contra Costa Water District 

1. The USER shares the District's concern for the protection 
of the San Francisco Bay-Delta system. As discussed in the 
groundwater and surface water sections of the Draft EIS, 
none of the alternatives is expected to impact the San 
Joaquin River or the Bay-Delta system. 

2. Kesterson Reservoir sediments have been analyzed for the 
toxic and bioaccumulative organic substances listed in 
Title 22 of the California Administrative Code. No levels 
were greater than the level of detection. 

3. This Final EIS contains a description of the USBR's 
proposed action which specifies decision points and crite- 
ria for contaminants. The proposed action also includes a 
viable contingency program for groundwater extraction in 
the event that contaminants exceed threshold levels. 



5-125 



County of 

jLne 26, 1986 



Public Works 8^ Development Seh^^jijpj^jiftiiie^t 



'Rictl^tfJdJXWelt«n 



velt«r 

C>irec|oi 



Mr. Alan Solbert 
Environmental Compliance Branch 
U. S. Bureau of Reclaration 
2800 Cottage Way, MP-750 
Sacramento, CA 95825-1898 

Dear Mr. Solbert: 

Subject: Draft Environmental Impact Statement, Kesterson Program 

Fresno County has reviewed and prepared a commentary on the Draft 
Environmental Impact Statement for the Kesterson Program. The County 
commentary is attached. 

After reviewing the draft EIS, the County of Fresno concludes that the 
draft Environmental Impact Statement (EIS) is deficient because of four 
major areas of concern. The County's areas of concern are: 

1. The long-range effects of closing Kesterson Reservoir. 

2. Development of criteria and standards for use in future 
selection of permanent water sources necessary to the wet-flex 
option. 

3. The negative enviromental and economic impacts of the "Nb 
Action" alternative. 

4. The alternative selection process. 

As a result of all of these deficiencies in the draft EIS, the document 
is inadequate. 

Thank you for the opportunity to comment on the draft EIS for the 
Kesterson Program. 

Very truly yours. 




Xct-i-^o^^ 



JerDy Boren 

Development Services Manager 



JB:PH:sl 
0926b 



5-126 



2220 Tulare Street. Suite 800. Fresno. California 93721/(209) 488-2992 
tquil Employmeni Opportunity - Affirmative Action - Handicap tmployer 



COMMENTS BY FRESNO COUNTY 

ON THE U.S. DEPARTMENT OF THE INTERIOR'S 

DRAFT ENVIRONICNTAL IKPACT STATEMENT FOR THE KESTERSON PROGRAM 



The draft Environmental Impact Statement (EIS) is deficient in that it does 
not adequately address: 

1. The long-range effects of closing the Kesterson Reservoir. 

- A regionally based analysis of the impact on the land, the people and 
the communities beyond the defined Kesterson area is needed. 

- A critical analysis of the long-range impacts that this action could 
have on regional water quality is omitted. Although an attempt is 
made to integrate the actions described in the draft EIS with other 
Bureau of Reclamation activities, Fresno County is concerned that the 
document does not adequately address these impacts nor the need for 
future ground water monitoring. 

- A detailed discussion concerning the initial drying-out of the 
Kesterson ponds needs to be included with emphasis on time frames, 
impact of the dry-out, and wtiether the dry-out may lead to 
mobilization of selenium. 

2. Development of criteria and standards for use in future selection of 
permanent water sources necessary to the wet-flex option. 

- On page VI of the draft EIS, statements are made regarding a 
temporary water source for the "Wet-Flex" alternative. The Bureau of 
Reclamation needs to develop criteria and standards for permanent 
water sources which may be selected. 



5-127 



- Baseo upon a recent letter, the Lawrence Berkeley Group has 
recommenaeo that the bureau of Reclamation "Put saline groundwater in 
the KR to keep the ponos wet, ana maintain an ecosystem nominated by 
Nitella ana cattails." Accoraingly, the Bureau neeos to adoress 
impacts from the use of fresh water (i.e., CVP interim water) versus 
saline water in the Kesterson Ponos upon the containment of selenium, 
ana the presence of selenium in the foodchain and the ecosystems in 
the Kesterson Reservoir. These are important issues because the 
Lawrence Berkeley Group makes the following statement: 

"Saline grounowater is preferable to fresh water in this 
application, because introaucing fresh water woulo profoundly 
perturb the ecosystem, very likely causing an invasion of many 
aifferent plant species, some of which will be able to remove 
selenium from the seaiment and put it into the fooochain," 

The negative environmental and economic impacts of the "No Action" 
alternative. 

- The estimated impacts for the "No-Action Alternatives" of the 
Kesterson Program oraft EIS ana the Plugging of the Drains araft EIS 
are inconsistent with one another. The impacts of the No-Action 
Alternatives for the two oraft EIS's shouio be similar, because the 
No-Action Alternatives for the two aocuments describe exactly the 
same situation, namely making no changes to the current situation 
with the San Luis Drain ana the Kesterson Reservoir. However, the 
statements from the two araft EISs are inconsistent with one another 
ana are in opposition to the oata ana analysis, particularly as 
presentee in the Kesterson Program oraft EIS. 

Baseo upon the information in the Kesterson Program draft EIS, we see 
the main significant aaverse effect is the perceiveo lack of ability 
of Los Banos ana Gustine to oiversify their economic bases. Although 
Fresno County consiaers the following figures to unoerestimate the 
real impact, baseo upon the statements in the araft EIS on San Luis 
Drain, the following are the main significant aaverse effects in 
western Fresno County: 

5-128 



















o 











Without a long-term drainage solution, "...most farmers would 
terminate farming operations within the study area." p. 119. 

there would be changes in cropping patterns; 

projected loss of 917 Jobs; 

projected loss of 2069 population; 

Projected loss of SSd dwelling units; 

annual public finance loss of $450,000; 

761 new families on welfare, total new welfare cost of $A.556 
million. 

There was no mention in the San Luis draft EIS about restriction 
of the Firebaugh and Mendota efforts, which have been underway, 
to diversify their economic bases. 



Clearly, in the Kesterson Program draft EIS, the economic base of 
that area would remain intact even if the Kesterson NWR were not 
cleaned-up. And not only would the economic base of the San Luis 
Drain draft EIS not remain intact, but also the economic base for the 
42,000 acres would be eliminated at the end of 10 years without the 
long term drainage solution. 

The draft EIS is deficient because in its no-action alternative 
analysis it claims that the effects on the Kesterson vicinity of 
continued flows are similar to the proposed project in Fresno County. 

We are of the opinion that the Kesterson program "No Action" 
alternative, keeps the economic base intact for the Kesterson 
vicinity, and thus the economic impacts in the Kesterson vicinity are 
in no way similar to the severe negative economic impacts on the 
economic base of the communities in Fresno County which will result 
from the recent plugging of the drains. 

5-129 



TTie alternative selection process. 

- Information or criteria by which a selected alternative would be 
evaluated Is not contained in the draft EIS. Criteria, an evaluation 
system, and proposed time frames must be developed to determine 
whether the selected alternative does or does not work. A process 
should also be described to indicate how the next alternative would 
be selected. 

- Discussion of potential funding for the various alternatives has been 
omitted as has been a discussion of the impacts of only partial 
funding on alternative selection. What would the impacts upon the 
program be if funding levels are insufficient? 

- The Bureau of Reclamation appears to underestimate the time frames 
necessary for public review of the regulatory process. For example, 
selection of either on-site disposal or incineration alternatives 
would require development of supplemental National Environmental 
Policy Act/California Environmental Quality Act documentation and 
design criteria to meet Subchapter 15, Title 23, California 
Administrative Code. In addition, permitting and environmental 
documentation time requirements average from 9 to 24 months. These 
time frames could make it impossible for some of the alternatives 
discussed in the draft EIS to be selected and still meet the February 
1988 deadline from the California State Water Resources Board. 



04768 



5-130 



Response to Comments of the Fresno County 
Public Works and Development Services Department 

The scope of the Kesterson Program EIS is limited to the 
cleanup of the Kesterson Reservoir. An examination of the 
land used and socioeconomic effects of the Secretary of the 
Interior's decision to close Kesterson Reservoir is beyond 
the scope of the EIS. The USSR's Contingency Program for 
Westlands Water District Drainage Disposal Project EIS 
(Contingency Program EIS) analyzes the land use and socio- 
economic impacts of ceasing drainage flows into the SLD 
which empties into Kesterson Reservoir. 

As described in response to comment 1 above, the impacts on 
regional water quality from the Secretary of the Interior's 
decision to close Kesterson Reservoir is beyond the scope 
of this EIS. The Contingency Plugging EIS also analyzes 
the water quality impacts of ceasing drainage flows into 
the SLD. 

The description of the proposed action contained in this 
Final EIS discusses these concerns. The southern ponds 
will not be allowed to dry out before flooding, thereby 
reducing risks of selenium mobilization. The northern 
ponds will be dry by March 1987. Impacts of these actions 
are described in the Draft EIS, and summarized in this 
Final EIS. 

This Final EIS contains a description of the USER ' s 
proposed action which specifies the criteria and standards 
for selecting a water source under each phase. 

Under the USBR's proposed action, the southern ponds would 
be flooded with moderate-salinity local shallow ground- 
water. This will avoid possible adverse ecological changes 
that could be caused by flooding the ponds with fresh 
water. 

The USER believes these comments are based on an incorrect 
assumption that the No-Action Alternatives are identical 
for the Kesterson Program EIS and for the Contingency 
Program EIS. Since the proposed actions are different, the 
No-Action Alternatives are different. For the Kesterson 
Program EIS, the No-Action Alternative assumes that dis- 
charges of drainwater to the SLD will have terminated by 
June 1986, pursuant to the DOI/WWD April 3, 1985 agreement. 
For the Contingency Program EIS, the No-Action Alternative 
assumes that discharges of drainwater to the SLD will 
continue, and that neither WWD nor USER will plug the SLD 
collector drains to terminate drainwater flows. The com- 
ments presented address impacts of the Contingency Program 
rather than impacts of the Kesterson Program, and are 
specifically responded to in the Contingency Program Final 
EIS. 



5-131 



This Final EIS contains a more detailed description of the 
user's proposed action plan than was contained in the Draft 
EIS. This Final EIS specifies the monitoring program, 
timeline, and decision points and criteria for evaluating 
the effectiveness of each phase of the proposed action. 

If Congress declines to appropriate the funds necessary to 
implement fully the proposed Kesterson Program, the Program 
will have to be modified accordingly. The ultimate deter- 
mination of which entity (or entities) will bear the cost 
of cleanup and postclosure maintenance of Kesterson 
Reservoir lands and/or the development of new waterfowl 
management areas is beyond the scope of this EIS. The 
Department of the Interior will, however, charge any compo- 
nent of such costs as are properly borne by CVP project 
users under existing reclamation laws to those entities. 
If it is subsequently determined that the allocation of the 
repayment obligation for the costs of the Kesterson 
Reservoir closure and cleanup actions may result in physi- 
cal environmental impacts, the USER will prepare supple- 
mental environmental documentation addressing these 
effects. 

Following completion of the Kesterson Program NEPA process, 
and SWRCE review of the CPMP , no further environmental 
documentation or public review will be necessary to 
implement the Onsite Disposal Plan. The USER agrees that 
the incineration alternative may require additional time 
for public review and environmental documentation assoc- 
iated with regulatory actions of other agencies. This 
alternative is not, however, included in USER'S proposed 
action. USER is confident that its proposed action can be 
implemented on a schedule consistent with the provisions of 
WQ 85-1, as amended by WQ 85-5. 



5-132 



DEPARTMENT OF 
PLANNING AND DEVELOPMENT SERVICES 



RANDALL L. ABBOTT 

DIRECTOR 

STEVEN G. LADO 
Assistant Director 



1103 GOLDEN STATE AVENUE 
BAKERSFIELD, CA. 93301-2499 

Planning Services (805) 861-2615 

Building Inspection (805) 861-2391 

Floodplain Management (805) 861-2892 



May 11, 1986 File: Agency 

U.S. Government 
Dept. of Interior 

Ms. Susan Hoffman 
Kesterson Program Manager 
U.S. Bureau of Reclamation 
2800 Cottage Way 
Sacramento, CA 95825-1898 

RE: DEIS - Kesterson Program 

Dear Ms. Hoffman: 

We have reviewed the above referenced document, and have no additional 
comments. Thank you for seeking our opinions. 

Very truly yours, 

RANDALL L. ABBOTT, Director 
Planning and Development Services 

By Peter F. Whitehead 
Senior Planner 



PFW:clm 



5-133 



Response to Comments of the Kern County 
Department of Planning and Development Services 

The USER appreciates Kern County's reviev/. 



d 



5-134 




WILLIAM E GNASS 
COUNTY COUNSEL 

OFFICE OF COUNTY COUNSEL 

2222 -M- STKirr 

AREA CODE (20t) MS-TM« 

MERCED, CALIFORNIA 9S340 



26 June 1986 



Susan Hoffman, MP-405. 

Program Manager 

United States Bureau of Reclamation 

Mid Pacific Regional Office 

2800 Cottage Way 

Sacramento, CA 95825-1898 

Re: Draft E.I.S. for Kesterson Cleanup Program 

Dear Ms. Hoffman: 

I have reviewed the above-mentioned document, and the 
response thereto of the Merced County Health Department 
dated June 26, 1986, attached hereto. I am in full agree- 
ment with the comments of Dr. Richard D. Welch, Merced 
County Health Officer, and Jeff Palsgaard, M.S., Director, 
Merced County Division of Environmental Health, and approve 
and adopt same as though set forth in full. 

I do have one addition to the response of the Merced County 
Health Department, that is amplification of the Page 4A-21 
comment. Z^y transportation of SLD sediments to the Kester- 
son Reservoir would be a violation of law as the reservoir 
is not a^^lid waste dump site. 

5ry trjuly yours. 



/ 
/ 


Merced^ 


E. GNASS 
rbunty Counsel 




WEG/dcl 








Attachme 


nt 





AN AFFIRMATIVE ACTION/EQUAL OPPORTUNITY EMPLOYER 

5-135 




DEPARTMENT OF HEALTH 

DMSION OF ENVIRONMENTAL HEALTH 
210 E. I5TH ST.. PC BOX 471 
MERCED. CALIFORNIA 9534 1 
(209)385-7391 



June 26, 1986 



Susan Hoffman MP-405 
Program Manager 
U.S. Bureau of Reclamation 
Mid Pacific Regional Office 
2800 Cottage way 
Sacramento, CA 95825-1898 



Dear Ms. Hoffman: 



The Merced County Health Department, Division of Environmental 
Health has reviewed the draft E.I.S. for the Kesterson Cleanup Program. 
All of our comments are based on the premise that Kesterson Reservoir is 
part of the Kesterson National Wildlife Refuge and should be returned 
to a safe wintering and feeding area for waterfowl in the Pacific Flyway. 

To accomplish this we feel the onsite disposal plan should be 
implemented as soon as the State Water Resources Control Board and Central 
Valley Regional Board have approved the cleanup plan. Advantages in 
implementing the onsite plan are as follows: 

1. The onsite plan has the least number of potentially 
significant unavoidable adverse impacts. 

2. The site is restored to a safe wildlife area. 

3. One time removal of vegetation. 

4. Little risk of contamination of new wetland vegetation. 

5. No significant leaking to groundv;ater since reservoir 
sediments have been removed. 

6. Hazing noise is eliminated. 

7. Reduces the risk of foraging. 
Disadvantages of using the phased approach include: 

1. Continuation of hazing noise. 

2. The existing problems of contaminated vegetation, wildlife, 
groundwater and poaching may continue. 



AN AFFIRMATIVE ACTION/EQUAL OPPORTUNlTf EMPLOYER 

5-136 



3. There is no guarantee the phased approach will work. 
The existing problems of contaminated vegetation, 
wildlife, groundwater and poaching may continue. 

4. Continuation of monitoring people working at the 
reservoir and living adjacent to the reservoir. 

General Comnents : 

Page 3-16: 

No mention is made of what criteria will be used with the phased 
approach to implement the different plans. For example, at what 
point has the Wet Flex Plan failed? Do increased levels of 
selenium found in groundwater indicate the Wet Flex Plan has 
failed? This is a significant area that has not been addressed 
in the E.I.S. 

Page 3-30: 

Since no specified use of the San Luis Drain (SLD) is being proposed 
south of Bass Avenue, the drain should be plugged at Bass Avenue 
to assure that no subsurface drainage water is drained into the SLD. 

Page 4A-21: 

Soil frotTi the SLD would be dryed at the reservoir and disposed in 
Pond #8. It is recommended that all SLD sediments be taken to an 
appropriate landfill site for disposal and not be disposed at 
Kesterson Reservoir. Storage of soil at the reservoir should be 
limited to what is currently at the reservoir. 

Page 4B-16: 

Air monitoring for particulates and selenium compounds should be 
included in the mitigation measures. 

Page 4D-1: 

All plans include programs for groundwater monitoring. Pesticides 
and sodium should be included in the monitoring program (EDB and 
D-D have been found in the surface water in significant amounts). 
Sodium has not been monitored and should be included in any ground- 
water monitoring program. 

Page 4D-3: 

The statement is made that "DWR concluded that the water was not 
used for any beneficial uses...". The Regional Water Quality,. 
Control Board has identified beneficial uses of the groundwater as 
irrigation and stock watering. 

Page 4E-2: 

The text states that "Malathion has been detected in one out of 
47 samples and phorate in three out of 47 samples." The text 
deletes the significant findings that 38 of 47 samples had 
detectable levels of D-D mixture and 17 of 47 samples had detectable 
levels of EDB. These levels of pesticides are significant and 
should be included in a groundwater monitoring program. 



5-137 



Page 4N-12: 

At what point would adjacent residents be temporarily relocated 
and who would be relocated? 

The State Water Resources Control Board cleanup and abatement should 
be included and referenced to the fact that the State and Regional Water 
Board must approve the plans before implementation. 

If you have any questions, please contact our office at (209) 385-7391, 



^ery truly vyo;jrs 



RT?f?ard'^Kwelch, M.D^ 




h Officer 



Jeff Palsgaard, M.S., Director 
Division of Environmental Health 



RDW/JP/jrd 

cc: Sarge Green 

Regional Water Quality 

Control Board 
3614 E. Ashlan 
Fresno, CA 93726 



5-13S 



Response to Comments of 
Merced County Counsel 

The Merced County Health Department concerns are addressed 
in responses to comments of the City of Gustine. 

The SLD sediments will not be transported under the USBR's 
proposed action as described in this Final EIS. If a 
subsequent decision to transport SLD sediments is made, all 
applicable state and local restrictions will be complied 
with. 



5-139 




m 



CALIFORNIA WATERFOWL ASSOCIATION 

3840 KOSIN COURT • SUITE 100 • SACRAMENTO, CA 95834 • (800)-424-DUCK • (916I-648-I40 



July 7, 1986 

Ms. Susan Hoffman, MP 405 
Program Manager, Pacific Region 
U. S. Bureau of Reclamation 
2800 Cottage Way 
Sacramento, CA 95825-1898 

Dear Susan: 

I really appreciated the opportunity of meeting with you on 
Monday to discuss the adequacy of the Kesterson DEIS. As I have 
pointed out previously, this DEIS is unusually comprehensive, 
thorough and detailed in its evaluation of the Kesterson problems 
and potential alternatives. Moreover, the innovativeness of two 
of the options and the "try it to see if it works" concept are 
approaches which I have never encountered before in 15 years of 
reviewing environmental documents. 

However, we have several concerns and suggestions with respect to 
the DEIS: 

1. Because the document is so comprehensive, technical and 
detailed, very few people will read it thoroughly and with 
sufficient knowledge to fully understand its implications. 
The summary on the other hand is almost skeletal and in my 
opinion overly condensed. I would suggest expanding it to 
roughly twice its present length in order to provide more 
detail on the various options without getting highly 
technical . 

2. The proposed monitoring program needs to be spelled out more 
fully and in our opinion should also deal with the question 
of who will do it. The Bureau's approach of "try the least 
expensive alternative and if it doesn't work going onto 
successively more elaborate ones until one does work" is 
certainly worth consideration. However, a disinterested 
third party such as the Environmental Protection Agency or 
the State Water Resources Control Board should decide whether 
or not a given effort has been successful, and this 
commitment should be included in the EIS. 



5-140 



I. A sub-alternative of both of the wet options contemplates the 
use of pumped saline ground water to maintain water levels. 
The impact, if any, of lateral movement of this water onto 
surrounding land should be evaluated. Further, due to evapo- 
transpiration of water in the ponds, the pumping in effect 
will mine the ground water. Conceivably, if the ground water 
is overdrafted, that condition could reduce lateral movement 
from the ponds. 

t. Based upon preliminary results obtained in the Grasslands the 
discing of pond bottoms should be evaluated. 

). Consideration should be given to using the San Luis drain 

from the Bass Avenue crossing north to the Crossroads for 

fresh water delivery to the Grasslands and to the Los Banos 
Waterfowl Area. 

1 6. Consideration should be given to the use of the San Luis 
drain from the Crossroads north to Mud Slough to convey 
drainage water generated within the Delta Mendota service 
area. 

7. The vegetative community which would result from the wet flex 
approach needs additional evaluation. Permanently flooded 
ponds with a maintained minimum water depth of twelve inches 
in my opinion would produce a vegetative monoculture with the 
dominant species dependent upon the salinity of the water. 
Initially, I would anticipate that it would be tules and 
bulrush. However, these plants have limited salinity 
tolerances, and I'm not sure what would grow as the salinity 
of the ponds increases due to evapotranspiration - perhaps 
spartina. In time they could get so salty that nothing will 
grow. In addition, there are other conditions associated 
with stagnant water sumps which need to be considered. In 
either case, you definitely would not be replicating the 
alternately flooded/moist soil conditions which would have 
existed in these ponds if they were being managed as the 
originally contemplated re-regulating reservoirs. In 
addition, their sump characteristics will over time result in 
much higher salinity levels than they would have experienced 
in their original configurations. 

8. The incremental cost of "wet harvest" should be presented. 

As you know from our discussion there are a significant number of 
other factors which are still of concern to us, and I was 
encouraged to find that they are still of concern to the Bureau. 
It sounds as though the answers to many of these will depend upon 
the ongoing research work being done by the Lawrence Berkeley 
Laboratory. It seems clear that those answers are needed before 
it is possible to make a valid evaluation of the wet flex 
alternative. 



Page 2 



5-141 



We appreciate this opportunity of commenting on the DEIS and hope 
that our input has been helpful. 

Vex-y^truly yours, 

D. Chapin, ChAarman 
Resources Committee 

DC: jm 

cc: CWA District 9 Directors 
Lee Lehman 



Page 3 5-142 



Response to Comments of the California Waterfowl Association 

1. The suggested change is editorial in nature and does not 
change the essential conclusions of the Draft EIS. The 
USER and its consultants have attempted to organize the 
Kesterson Program EIS in a manner that is both informative 
and easy to follow. It is recognized that other editorial 
approaches could have also accomplished these goals. A 
less technical summary of the Draft EIS was prepared by the 
USER and released to the public as Kesterson Program Fact 
Sheet Number 2 . 

2. The Final EIS more fully describes the monitoring program 
that will be implemented as part of the proposed action, 
including the role of agencies other than USER in reviewing 
monitoring data and USER decisions. 

3. The USER will supply the Reservoir with moderately saline 
water to preserve the habitat that has been established at 
Kesterson Reservoir over the past several years. The 
shallow aquifer is the most convenient source of saline 
water for the Reservoir. 

Water has been applied to the Reservoir for the last 
several years, therefore, the continued application of 
water will not significantly increase the lateral flow away 
from the Reservoir. In fact, by supplying the Reservoir 
with local groundwater removed from wells along the eastern 
perimeter of the Reservoir, any lateral flow that does 
occur from the east will, be captured and reapplied to the 
Reservoir. Any flow to the west will be intercepted by Mud 
Slough. 

Preliminary data from wells the USER has installed along 
the eastern perimeter of the Reservoir indicate that the 
shallow aquifer can sustain yields in excess of 5,000 
acre-feet per year without significantly impacting 
groundwater levels in the area. However, for the reasons 
suggested above, and because water levels below the 
Reservoir will be less, lateral movement onto the 
surrounding land will be reduced. 

4. The proposed action includes research on discing 
effectiveness, followed by discing of the northern ponds to 
eliminate vegetation as part of the FRP. 

5. Specific use of the SLD between Bass Avenue and the Cross- 
roads is not part of the proposed action. The SLD, how- 
ever, will be maintained for future use through application 
of water from the DMC or local shallow groundwater. The 
purpose of applying water to the SLD is to preserve the 
structure and to keep accumulated sediments covered. 



5-143 



6. The SLD adjacent to Kesterson Reservoir v/ill be used as a 
clean water conveyance facility as part of the proposed 
action. It would not be possible to use that portion of 
the SLD for conveyance of drainwater. 

7. Vegetation resulting from FRP conditions in the wet ponds 
will most likely be similar to that presently in Ponds 1-5 
and 7. Open water will cover larger areas. 

Salinity will increase at a slower rate than in the past, 
because local groundwater will be applied that has lower 
TDS levels than previously applied drainwater. Salinity 
v/ill be less seasonally variable, because water will be 
maintained at a 3-4 foot depth throughout the year. These 
factors will help to maintain brackish rather than highly 
saline conditions over the long term. 

Areas that eventually become highly saline will support 
less emergent vegetation and more wigeon-grass ( Ruppia ) , 
N itella , and associated algae and bacterial tolerant of 
relatively high salinity. Spartina will probably not 
appear, because it is not known to occur in the vicinity 
and it does not persist under conditions of permanent 
flooding. 

8. The capital cost of wet harvesting, without regard to dis- 
posal, IS approximately $2,500,000. 

9. The Final EIS specifies monitoring criteria and decision 
points as part of the proposed action for determining the 
effectiveness of the phased approach. 



5-144 




Chapman Forestry Foundation 

RESEARCH AND DEVELOPMENT 

P.O. Box 311 • Davis. California 95617 



June 27, 1986 




Susan Hoffman 
Kesterson Program Manager 
U.S. Bureau of Reclamation 
2800 Cottage Way 
Sacramento, CA 95825-1898 

Dear Ms. Hoffman: 



RE: DE15 - Kestersoti'T^ogram 



Our comments revolve to one question - Why spend all 
this taypayer money on a sump? Why not let the Kesterson 
Reservoir area dry out and immobilize itself? The annual 
precipitation of about 10 inches is not enough to form more 
than very temporary ponds at best, and the population of 
wildlife would be a very minimum. 

The expenditure of additional funds on this project 
would be a further waste of taxpayer funds, and should 
be stopped. If money is spent, it should be for better 
quality water for the duck clubs. 

Sincerely yours, 




«-*- 



A. Dale Chapmj 
CHAPMAN FORESTRY FOUNDATION 
(Owner of the 788A Zimmerman 
Club) 



5-145 



For the Wise and Multiple use of Our Natural Resources 



Response to Comments of the Chapman Forestry Foundation 

1. Significant adverse impacts would result from maintenance 
of a uniformly dry reservoir. These impacts were evaluated 
under the FRP dry option and described in the Draft EIS. 

2. The Final EIS proposed action discusses the potential for 
supplying water to offsite wetlands (including private 
lands) as a mitigation measure. 



5-146 



nJefcndcrs 



OF WILDLIFE 



June 30, 19 86 



Susan Hoffman 
Kesterson Program Manager 
U.S. Bureau of Reclamation 
2800 Cottage Way 
Sacramento, CA 95825-1898 

Dear Ms. Hoffman: 

Defenders of Wildlife submits this letter as our comments and 
recommendations on the Draft Environmental Impact Statement (DEIS) 
entitled "Kesterson Program" (#DES 86-21). As you may know, we 
have a longstanding interest in the protection of Kesterson National 
Wildlife Refuge, and in the elimination of wildlife deaths and 
deformity associated with selenium contamination and the San Luis 
Drain. 

With this background in mind, we have reviewed the DEIS and we have 
a number of serious concerns with respect to the DEIS and the Bureau's 
proposed "phased approach" to Kesterson clean-up. We believe that 
this phased approach may not fulfill the February 1988 clean-up 
deadline. If monitoring demonstrates failure of the first and perhaps 
the second phases, it is likely to be too late to successfully implement 
a subsequent phase. We question the Bureau's willingness to "gamble" 
on the flexible response and immobilization plans (which we find very 
similar) , when the onsite or of f site disposal plans are obviously 
more capable of isolating and removing selenium from the environment. 
It appears that the Bureau is improperly biased toward initial 
implementation of the least expensive clean-up methods, despite the 
relatively greater risks of continuing environmental contamination 
and exceeding the deadline. This bias may even be short-sighted from 
an economic standpoint since an individually more expensive disposal 
plan would still be cheaper than having to implement three phases to 
achieve eventual compliance with the clean-up requirements. 

The DEIS does not describe when, how, or by whom monitoring may show 
that a phase has failed because of "unacceptable contamination" (page 
3-16) . Clear and specific guidelines must be adopted which dictate 
who conducts monitoring, when, and what levels constitute "unaccept- 
able contamination." We recommend that an interdisciplinary team of 
independent scientists and agency personnel (Bureau, FWS , SWRCB, USGS, 
etc.) conduct comprehensive monitoring of soil, water, air, and wildlife 
on a frequent basis (perhaps monthly) , with their findings available to 
the public. We similarly recommend that the establishment of guidelines 
on "unacceptable contamination" levels be implemented by this objective, 
interdisciplinary approach. This could alleviate public fears concerning 
the Bureau's previous handling of Kesterson/selenium data. 

CALIFORNIA OFFICE; 5604 ROSEDALE WAY. SACRAMENTO, CALIFORNIA 95822 • (916) 442-6386 

NATIONAL OFFICE: 1244 NINETEENTH STREET, NW • WASHINGTON, DC 20036 • (202) 659-9510 

5-147 



IDefmdcrs 



OF WILDLIFE 

-2- 



Due to generic concerns relating to monitoring, mitigation, and 
other aspects covered in the DEIS's alternative plans, we do not 
endorse any particular plan at this time. We generally prefer, 
however, the offsite disposal plan's approach since it offers 
the best hope for removing selenium contamination and protecting 
refuge values. 

While we understand that the U.S. Fish and Wildlife Service's formal 
Biological Opinion under Section 7 of the Endangered Species Act is 
not yet available (and presumably will be incorporated in the Final 
EIS) , we nevertheless wish to convey our concern that implementation 
of any plan other than prompt off-site disposal may violate the 
Endangered Species Act, and harm one or more of the listed and 
candidate species described in the DEIS (Table 4-41) . Given the 
overall failure of the hazing efforts, the known bioaccumulation of 
selenium, and the presence of abundant weakened prey on and near 
Kesterson Reservoir, we are particularly concerned that listed and 
candidate predator or scavenging species--the San Joaquin kit fox. 
Bald eagle, American peregrine falcon, Swainson's hawk, etc. --may be 
jeopardized. Data from the recent small mammal study reinforces 
this concern. 

We generally support and applaud the Bureau's commitment to fully 
mitigate the loss of wetland habitat under each plan described in 
the DEIS. However, the DEIS fails to adequately distinguish the 
permanent and seasonal wetland habitat values contrasted between 
the southern and northern Kesterson Reservoir ponds. Both wetland 
habitat types are important, and we recommend that "in kind" mitigation 
be implemented which seeks to duplicate the acreage of each habitat 
type to correspond with habitat losses in the respective Kesterson 
Reservoir ponds. Unfortunately, the DEIS's mitigation measures also 
fail to reconcile short-term habitat losses, including the likely 
"gap" between the expected habitat losses and the two or more years 
needed to establish alternative "new" wetlands of suitable quality. 
We strongly recommend that the Bureau make a firm commitment to 
provide both long-term and interim mitigation. To fulfill the 
interim mitigation commitment, we further recommend that the Bureau 
expeditiously support and implement the wetland related projects 
described in the June 9, 1986 Memorandum to you from the San Luis 
NWR Complex Manager (subject: "Interim Mitigation Projects - Kesterson 
NWR.") . Time is of the essence because of the continuing harm to 
wildlife from ongoing selenium contamination, and because of seasonal ^^ 
limits on the ability to effectively provide water in anticipation of ^| 
the Fall arrival of migratory species. ^^ 

We urge the Bureau to support consideration of the removal of selenium B^ 
from the San Luis Drain, and the Drain's subsequent use to deliver ^^ 
clean water for wetland habitats. While we appreciate the Bureau's 
past efforts in providing water for wetlands, we recommend that the 
Bureau make a detailed, long-term commitment to provide water of H 
10 adequate quality and quantity to maintain the wetland habitats « 

associated with both interim and long-term mitigation. 

5-148 ■ 



P 



njcfcndcrs 

_y OF WILDLIF 



LDLIFE 

-3- 



Finally, we remain deeply concerned at the continuing uncertainty 
with respect to the U.S. Fish and Wildlife Service's long-term 
authority to manage and protect the Kesterson National Wildlife 
Refuge. As you know, this refuge was created in a cooperative 
agreement between the Bureau and FWS . The refuge's legal status 
appears subject to the Bureau's operation of the San Luis Drain. 
Since there are now federal and state orders to terminate the Drain's 
use for agricultural drainage, and there is no longer any prospect 
of expanding Kesterson Reservoir or extending the Drain, we recommend 
that the Bureau make a commitment to transfer the full legal title 
and management of Kesterson Refuge to the FWS at least upon 
compliance with the clean-up requirements. Indeed, the ultimate 
1]^ fate of Kesterson Refuge should be candidly addressed and considered 
in evaluating mitigation measures. For example, if the Bureau 
does not decide to transfer its refuge authority to the FWS, then 
the reasons for this decision should be explained and any Bureau 
proposals for future developments on this 5,900 acres disclosed. 
As indicated in earlier correspondence and meetings with Regional 
Director Houston, we believe that the best public use of this 5,900 
acres is in maintaining and restoring natural habitat values. 

Please keep us informed of any Bureau decisions or actions relating 
to this DEIS, the San Luis Drain, Kesterson Reservoir, and Kesterson 
Refuge. Please send us a copy of the Final EIS on the Kesterson 
Program to the Sacramento address on the first page of this letter. 



Thank you very much for considering our views, 
Si<^cerely , 



i<icer( 




Richard 'Spotts 
California Representative 
Defenders of Wildlife 

cc: Interested parties 

RS/bc 



5-149 



Response to Comments of the Defenders of Wildlife 

1. The USER shares the Defenders of Wildlife's interest in the 
protection of wildlife at Kesterson National Wildlife 
Refuge. The USBR's interpretation of WQ 85-1 is that the 
February 1988 date is the date by which implementation of a 
cleanup plan is to be initiated, not completed. 

2. See discussion of FRP risks in Chapter 3 of this Final EIS. 

3 . The Final EIS contains a description of the proposed action 
which is more detailed than that contained in the Draft 
EIS. The Final EIS proposed action specifies monitoring 
criteria and decision points to evaluate the effectiveness 
of the phased approach. 

4. This Final EIS describes the monitoring program that will 
be implemented as part of the proposed action. The USER 
will have ultimate responsibility for the monitoring pro- 
gram. Monitoring results will be shared with other 
agencies and the public, as described in the proposed 
action description. 

5. The USER shares the commenter's concern regarding potential 
adverse effects to listed and candidate species under the 
FRP. The USER recently prepared a Eiological Assessment 
for listed and candidate wildlife and plant species. This 
document summarizes the status and distribution of four 
mammal species, nine bird species, two reptile species, one 
amphibian species, and nine plant species at Kesterson 
Reservoir and the areas which have been proposed for off- 
site compensation (Gallo and Wolfsen properties) . Three 
wildlife species--San Joaquin kit fox (listed endangered 
species) , western snowy plover (candidate species) , and 
tricolored blackbird (candidate species) — and one plant 
species--San Joaquin saltbush (candidate species) --could 
potentially experience adverse effects under the proposed 
plan, although the proposed action would not jeopardize the 
continued existence of any of these species. 

The Biological Assessment addresses these adverse effects 
(including the continued risk of contamination and loss of 
habitat) and describes potential conservation measures for 
each species. 

6. Comment noted. Mitigation could take the form of providing 
water supply to offsite wetlands as an alternative to the 
purchase and development of offsite wetlands. 

7. The DOI is considering both short-term and long-term miti- 
gation, as described in the proposed action description 
contained in this Final EIS. 



5-150 



8. USER is proceeding with implementation of alternative 
habitat projects referenced in this comment. 

9. The description of the proposed action in this Final EIS 
addresses potential uses of the SLD. To preserve flexibil- 
ity in the future use of the SLD, it is not proposed that 
the SLD be used for delivery of fresh water. 

10. The Final EIS discusses the provision of water to possible 
mitigation lands from each of the identified alternative 
sources . 

11. This issue is beyond the scope of the EIS. Ultimate 
ownership and management will depend on the ultimate 
outcome of USBR's proposed phased approach. 



5-151 



ENVIRONMENTAL DEFENSE VlMm 

June 27, 1986 



2606 Dwight Way 
Berkeley, C A 94704 
(415)548-8906 



National Headquarterb 

444 Park Avenue South 
New York. NY 10016 
(212)686-4191 



1525 18th Street, NW 
Washington, DC 20036 
(202)387-3500 

1405 Arapahoe Avenue 
Boulder, CO 80302 
(303)440-4901 

11 South 12ih Street 
Richmond, \A 23219 
(804) 780-1297 



Susan Hoffman 
Kesterson Program Manager 
U.S. Bureau of Reclamation 
2800 Cottage Way 
Sacramento, CA 95825-1898 



RE: Draft Environmental Impact 

Statement on Kesterson Program 



Dear Ms. Hoffman: 



The Environmental Defense Fund has reviewed the Draft 
Environment-al Impact Statement for the Kesterson Program and| 
offers the following comments. Generally, while we 
appreciate the difficult time constraints faced by the 
Bureau and the various cooperating agencies, in our view the 
DEIS does not fully address several issues pertinent to 
devisirvg an effective and environmentally sound cleanup and 
mitigation program. 

Future Decision Making 

The proposed action would set into motion a long-term 
plan to try various options and, based upon the success of 
each option, to make decisions for future actions. However, 
it is unclear how and when the success or failure of the 
options will be evaluated. There is an apparent possibility 
that after the State Water Resources Control Board approves 
a plan, there will be no further public input, and that the 
remainder of the Kesterson clean-up will proceed under 
completely internal processes. 

We suggest that addendums to the EIS, including public 
review and comment, should be prepared at major decision 
points in the program. At a minimum, addendums should be 
prepared to describe, in detail, the specific plans for 
implementation of each option and the proposed method of 
evaluating its success. The addendums or the final EIS 
should also include pertinent information that ig expected 
to become available over the course of the next few months, 
such as information regarding the concentration and rate of 
decrease of selenium in food chain plants and estimates of 
the mass balance of selenium in the p>onds. This information 
is crucial to an adequate understanding of the impacts of 
the projKJsed cleanup alternative since it relies on the as 



C»>w 



5-152 



Susan Hoffman 
June 27, 1986 
Page 2 



yet unverified assumption that selenium will either remain 
bound to pond sediments or diluted in the environment at 
non-harmful concentrations. 

Finally, if the flexible resp>onBe option is selected, 
it should be made explicit that selenium concentrations 
would not be the only measure of the success of the plan. 
Other elements (e.g., boron) should be measured as well. The 
FEIS should also directly address plans for the northern 
ponds, which we understand have been allowed to dry, while 
the southern ponds have been kept flooded with clean well 
water. 

Mitigation for Loss of Wetlands 

The reliance on onsite mitigation for the loss of 
wetlands is misplaced. First, even under the best case 
scenario described on page 3-18, which assumes the success 
of the flexible response option and restoration of onsite 
wetlands, there would apparently be a minimum time lag of 
several years after the beginning of the program (to which 
must be added, of course, the additional time lag before the 
program begins) before waterfowl hazing is discontinued and 
the reservoir is presumably a viable wetland. During this 
period there wiU be continued risk to wildfowl, especially 
given the failures of the hazing program. Ultimately, 
because of the uncertainty as to whether the flexible 
reponse plan will work, there is a significant chance that 
off-site creation of wetlands will bs necessary. 

Instead, to provide adequate wildfowl habitat, the 
Bureau, in conjunction with the U.S. Fish and Wildlife 
Service, should proceed now with off-site wetlands 
mitigation. The costs of this mitigation should be 
internalized within the CVP, and it should entail no 
additional CVP Delta exports. If restoration of the 
Kesterson wetlands does some day occur, the question of 
who should pay for additional wetland habitat can be 
addressed at that time. 

Water Supply 

Each of the options requires delivery of clean water 
from the CVP. However, the DEIS defers discussion of 
long-term water supply options to the Central Valley Basin 
Refuge Water Supply Investigation and the Bureau's CVP water 
marketing program and associated NEPA documentation. It is 
unclear whether the Bureau intends that the "temporary" 
supply of water associated with the Kesterson cleanup and 



5-153 



Susan Hoffman 
June 27, 1986 
Page 3 



mitigation will entail additional exports from the 
Sacramento-San Joaquin Delta. 

The water supply for cleanup and mitigation should 
come from existing CVP export supplies. Increasing exports 
would be especially inappropriate given the lack of any 
analysis in the DEIS of the effects of water supply 
alternatives on Bay/Delta resources. A related and equally 
important question is who is going to pay for the necessary 
water. In our view, the cost of the water should be 
internalized within the Central Valley Project. 

Treatment Alternatives 

The DEIS generally gives inadequate consideration to 
treatment options. In particular, it overestimates the cost 
of reverse osmosis because of its reliance on CH2M Hill 
figures. The FEIS should also reflect recent research and 
pilot studies in selenium removal, including chemical 
treatment, biological treatment, and physical removal 
through harvesting algae in the ponds. Such treatment 
options should be considered in conjunction with the other 
options (e.g., the flexible response option). The Bureau 
should evaluate the potential for incorporating treatment 
and removal systems in any cleanup option, rather than 
relying solely on a poorly understood "solution" of 
containment and dilution. 

We appreciate the opportunity to present these 
comments. Please do not hesitate to contact us if you ^vish 
to discuss any aspect more fully. 

Sincerely, 




I4f%c^(lf 



ohn W. Krautkraemer 
ttorney 



Terry F. Young, Ph.D. 
Consulting Scientist 

Bryan Wilson 
Legal Intern 



5-154 



Response to Comments of the Environmental Defense Fund 

1. The proposed action description contained in this Final EIS 
describes methods to be employed for judging the success of 
the FRP, and methods for obtaining public and agency input 
following plan implementation. The USER intends to keep 
agencies and the public fully informed about monitoring 
program results and future decisionmaking. 

2. The proposed action description contained in this Final EIS 
describes specific implementation plans for the Flexible 
Response, Immobilization, and Onsite Disposal Plans, and 
methods for evaluating the success of each. 

3. See discussion of FRP risks in Chapter 3 of this Final EIS. 
Research continues to be conducted by LBL regarding the FRP 
and Immobilization Plan, but the LBL research results at 
this time are still preliminary. The USER has no plans at 
this time to prepare future Kesterson Program EIS sup- 
plements based solely on results of research conducted 
after distribution of this Final EIS. It is required to do 
so only if significant new information is developed rele- 
vant to environmental concerns related to the proposed 
action. 

4. The Final EIS proposed action description describes the 
specific monitoring program and operating plan to be imple- 
mented for each pond. 

5. The proposed action described in this Final EIS describes 
mitigation alternatives under consideration. 

6. Water supply alternatives for potential off site mitigation 
wetlands are described in both the Draft EIS and Final EIS. 
The USER is currently evaluating these alternatives. 
Interim CVP water supplies being considered for mitigation 
would not entail additional exports from the Sacramento-San 
Joaquin Delta (see discussion of FRP impacts in Chapter 3 
of this Final EIS) . 

7. The ultimate determination of which entity (or entities) 
will bear the cost of cleanup and postclosure maintenance 
of Kesterson Reservoir lands and/or the development of new 
waterfowl management areas is beyond the scope of this EIS. 
The Department of the Interior will, however, charge any 
component of such costs, as are properly borne by CVP 
project users under existing Reclamation laws, to those 
entities. If it is subsequently determined that the allo- 
cation of the repayment obligation for the costs of the 
Kesterson Reservoir closure and cleanup actions may result 
in physical environmental impacts, the USER will prepare 
supplemental environmental documentation addressing these 
effects . 



5-155 



m 



The costs for reverse osmosis are based on the CH2M Hill 
report to the USBR entitled "Reverse Osmosis Desalting of 
the San Luis Drain." 

A wide variety of treatment options was considered in the 
development of alternatives. A description of these op- 
tions and their screening is contained in Appendix I of the 
Draft EIS. 



m 






5-156 



^ 



OFFICERS 

JOHN E PUCHEU. JR 
PRESIDENT 

GEORGE LINDEMANN 
VICE-PRESIDENT 

DANIEL NELSON 
SECRETARY 
STEPHEN K HALL 
EXECUTIVE DIRECTOR 
TREASURER 



Land Preservation Association 

770 E. Shaw Avenue, Suite 205 • Fresno CA 93710 

(209) 227-1695 • Telecopier Call (209) 227-1695 



June 18, 19 86 



ni RECTORS 

BILL CAMP 
ALLEN COUTCHIE 
WILLIAM R JOHNSTON 
GEORGE LINDEMANN 
DON MARCIOCHI 
MIKE PEREZ 
MIKE PORTER 
JOHN E PUCHEU, JR 
JACK H THRELKELD 
CRAIG T ULRICI 
JOHN E WILLIAMS 



Ms. Susan E. Hoffman 

Program Manager, Kesterson Program 

U. S. Bureau of Reclamation 

2800 Cottage Way 

Sacramento, CA 95825-1898 

Re: Kesterson Program, Draft EIS 



Dear Ms. Hoffman: 

This letter is submitted on behalf of Land Preservation 
Association and its member agencies, and is in response to 
the Draft Environmental Impact Statement prepared for the 
Kesterson Reservoir Cleanup Program. The comments contained 
herein are general in nature and are not intended to be a 
full and complete recitation of the positions held on 
Kesterson Reservoir by LPA and/or its members. 

In comparing the cleanup alternatives listed in the EIS, it 
appears that the Flexible Response Plan (wet option) is the 
best alternative from a number of standpoints. The 
combination of flexibility, low cost and high degree of 
environmental protection embodied in this option are the 
most striking advantages. From the description given in the 
EIS, it appears the Flexible Response Plan could be employed 
by itself or in combination with one or more of the other 
options described, making it the most versatile alternative. 
Its estimated cost is several times less expensive than the 
Flexible Response (dry option) and many times less expensive 
than off site disposal, which is the most expensive option. 
Finally, the environmental protection offered by this option 
appears to equal or exceed the other alternatives studied. 

In addition to the significant advantages described above, 
the Flexible Response Plan (wet option) may provide other, 
less obvious, benefits; such as opportunities for future 
research in the area of selenium behavior in an aquatic 
environment, continued use of the area as a waterfowl 
resting area, preservation of existing facilities in the 
event the reservoir can once again be used as a refuge marsh 
facility, and, finally, the possibility that drainage water 



5-157 

MEMnr.K \(,E\CIES 

BROADVIEW WATER DISTRICT • CENTRAL CALIFORNIA IRRIGATION DISTRICT • COLUMBIA CANAL COMPANY • FIREBAUGH CANAL COMPANY 

GRASSLAND WATER DISTRICT • PACHECO WATER DISTRICT • PANOCHE DRAINAGE DISTRICT • SAN LUIS CANAL COMPANY 

SAN LUIS WATER DISTRICT • TRANQUILLITY IRRIGATION DISTRICT • WESTLANDS WATER DISTRICT 



Ms. Susan E. Hoffman 
June 18, 19 86 
Page 2. 



which has been treated to remove selenium and other 
potential contaminants could be used in place of fresh water 
to maintain the area. 

Of courser it is quite possible that none of these secondary- 
benefits would result. Further, it is possible that the 
Flexible Response Plan (wet option) will not function as 
expected and, under certain circumstances, the combination 
of this option and others could actually be more expensive 
than some of the other options which are more expensive 
initially. That being the case, LPA strongly urges that 
studies, which we understand are planned to field test this 
option, be conducted carefully and thoroughly. 

There is another issue which is not within the scope of the 
draft EIS, but which is an integral part of the Kesterson 
Program and which should be addressed at an early date in a 
way that allows local interests to provide input. That 
issue is the question of who shares the cost of the 
Kesterson Cleanup and related programs. In fact, there are 
many outstanding questions about the assignment of costs for 
the entire San Joaquin Valley Drainage Program. For 
instance, the draft EIS mentions that Central Valley Project 
water will be used to establish and maintain the Flexible 
Response (wet option); however, no mention is made of what 
CVP account (s) that water will be drawn from. While the 
amount of water is not a significant part of the overall CVP 
supply, that question, and many other, more compelling, 
questions of cost must be answered before the plan is 
implemented. 

We understand that current policy calls for all costs 
associated with the San Joaquin Valley Drainage Program to 
be assigned to the San Luis Unit. It is the position of 
Land Preservation Association and its member agencies that 
the costs associated with the Kesterson Cleanup and many of 
the San Joaquin Valley Drainage Program study costs should 
be spread far more broadly than to the San Luis Unit. We 
urge you to begin addressing this issue soon. 

In summary, we support the Flexible Response Plan (wet 
option) and the tests which are planned to verify its 



5-158 



Ms. Susan E. Hoffman 
June 18, 1986 
Page 3. 



effectiveness. We also urge you to address cleanup and 
study cost repayment. Finally, we thank you for the 
opportunity to comment on your work and look forward to 
future such opportunities. 



Sincerely, 

LAND PRESERVATION ASSOCIATION 




Stephen 

Executive Director 



SKHrdv 

cc: Honorable Ken Maddy, Attn: Jo-Ann Slinkard 
Honorable Rusty Areias, Attn: Gail Pellerin 
Honorable Jim Costa, Attn: Bob Reeb 
Honorable Bill Jones, Attn: Mike Chrisman 
LPA Board Members 
Cecil Carey 
Jack Gualco 
Bill Jones, Sr. 
Dan Nelson 



5-159 



Response to Comments of the Land Preservation Association 

The USER appreciates the commenter's interest. The USBR's 
proposed action incorporates the FRP as part of the phased 
approach described in the Final EIS. 

The ultimate determination of which entity (or entities) 
wij 1 bear the cost of cleanup and postclosure maintenance 
of Kesterson Reservoir lands and/or the development of new 
waterfowl management areas is beyond the scope of this EIS. 
The Department of the Interior will, however, charge any 
component of such costs as are properly borne by CVP proj- 
ect users under existing Reclamation laws to those enti- 
ties. If it is subsequently determined that the allocation 
of the repayment obligation for the costs of the Kesterson 
Reservoir closure and cleanup actions may result in physi- 
cal environmental impacts, the USER will prepare supple- 
mental environmental documentation addressing these 
effects . 



5-160 




National Audubon Society 

Western Regional Office 
5SS AUDUBON PLACE. SACRAMENTO. CA 95825 (916) 481-5332 



July 8, 1986 



Ms. Susan Hoffman 
Kesterson Program Manager 
U.S. Bureau of Reclamation 
2800 Cottage Way 
Sacramento, CA 95825 

Dear Ms. Hoffman: 

Attached are the comments of the Western Regional Office of the National 
Audubon Society on the draft Environmental Impact Statement for the cleanup of 
Kesterson Reservoir and the San Luis Drain. We appreciate the opportunity to 
participate in the review of plans for carrying out this important activity. 

A "phased" approach to cleanup of Kesterson Reservoir is proposed. Four 
action plans and a no-action option are discussed. If the preferred option, 
called the "wet-flex" plan, should fail, other plans — more costly, but much 
more likely to accomplish the desired results — would be implemented. 

Little evidence is presented which would engender a feeling of confidence 
that the "wet-flex" plan will work. The plan is based largely on theory, 
backed by limited laboratory analysis, but no long-term field testing on a 
significant scale. In our view, its potential to even meet the cleanup 
objectives established by the State Water Resources Control Board, much less 
to meet them within the required time frame, is essentially nil. Its 
implementation will certainly result in continued violations of the Migratory 
Bird Treaty Act. 

Furthermore, the DEIS does not set forth adequate criteria to establish 
the line between an acceptable and an unacceptable level of contamination. As 
a consequence, it cannot define how any of the plans will be judged to have 
met (or not to have met) the cleanup objectives. Neither does it spell out 
who will make that determination, nor provide for any public input into the 
process. 

Finally, the DEIS does not contain plans to offset the fish and wildlife 
losses which have already occurred, and continue to occur, at Kesterson 
Reservoir and along the San Luis Drain. This shortcoming must be overcome. 



5-161 
AMERICANS COMMITTED TO CONSERVATION 



Susan Hoffman 
July 8, 1986 
Page 2 



It is our understanding that the U.S. Fish and Wildlife Service has 
recommended a cleanup plan for Kesterson Reservoir and the San Luis Drain 
which would eliminate environmental contaminant hazards to fish and wildlife 
resources, and fully compensate for both interim and long-term habitat 
losses. A significant feature of that plan is the cleanup of the San Luis 
Drain to permit its use for delivery of good quality water. Based on our 
review of that plan, we believe it to be superior to any of the options set 
forth in the DEIS. We urge you to adopt this plan as your preferred 
alternative in the final EIS, 



Thank you for your consideration of our views. 

Sincerely, 



DANIEL TAYLOR (y 
Regional Representative 



DT/cr 



5-162 



Response to Comments of the 
National Audubon Society 

See discussion of FRP risks in Chapter 3 of this Final EIS. 
The USER believes that the proposed action will meet the 
SWRCB ' s cleanup objectives and schedule. 

The USER has taken into account the provisions of the 
Migratory Bird Treaty Act in developing its proposed action 
for the cleanup and closure of Kesterson Reservoir. The 
proposed action incorporates adequate safeguards to fulfill 
the user's responsibilities under this and other statutes 
intended to protect migratory birds or other fish and wild- 
life resources. It is the USER'S view, which is supported 
by advice from the Department of Justice, that the Migra- 
tory Eird Treaty Act does not proscribe the activities of 
federal officials who carry out their statutory respon- 
sibilities with due care and in good faith, even though the 
activities might result in incidental bird deaths. 

Decisionmaking criteria and the decisionmaking process for 
the phased approach are described in the proposed action 
description in this Final EIS. 

Mitigation alternatives being considered are described in 
the proposed action description contained in this Final 
EIS. 

Comment is noted. Mitigation alternatives are described in 
this Final EIS. 



5-163 



tmi 



Natural Resoum 
Defense Council 



25 Kearny Street 

San Francisco, CA 9416 



June 27, 1986 



Federal Express 



Mr. David Houston, Director 
Mid-Pacific Region 
Bureau of Reclamation 
2800 Cottage Way 
Sacramento, CA 95 825 



Re: Draft Environmental Impact Statement 
Kesterson Program 

Dear Mr. Houston: 

Enclosed are the comments of the Natural Resources 
Defense Council on the Draft Environmental Impact Statement 
Kesterson Program (DEIS) . While we commend the Bureau for 
its effort to develop an urgently needed cleanup plan for 
Kesterson in a short period of time, we cannot endorse the 
"wet-flex" plan preferred by the Bureau. That plan would 
fail to satisfy the Bureau's legal obligations under the 
Migratory Bird Treaty Act and the State Water Board's Cleanup 
and Abatement order. Our comments describe a number of other 
criticisms of the proposed plan and the DEIS. 

Thank you for considering our views. 



Sincerely yours, 

Laura B. King ^ 
Senior Scientist 



lUOr, RecucUd fafcr 



Neu' York Office: 

122 East 42nd Street 
New York. Mew York W16S 
212 949-0049 



5-164 

Washington Office: 
1350 Neu'York Ave, N.W. 
Washington, DC 20005 
202 783-7S00 



Nciv Enghind Office: 
850 Boshm Post Road 
Sudbury, MA 01776 
617 443-6300 



Toxic Substances 
Information Line 
USA: 1-800 64S-SRDC 
N)'S:2U687-6l>62 



COMMENTS OF THE 
NATURAL RESOURCES DEFENSE COUNCIL, INC. 

ON THE 



BUREAU OF RECLAMATION DRAFT ENVIRONMENTAL 
IMPACT STATEMENT: 



June 27, 1986 



KESTERSON PROGRAM 



Prepared by: 

Diane Regas 
Laura B. King 
Hamilton Candee 



5-165 



I. Introduction 

These are the comments of the Natural Resources Defense 
Council (NRDC) on the Bureau of Reclamation's Draft Environmental 
Impact Statement (DEIS) for the proposed Kesterson Program. NRDC 
is a national nonprofit organization of over 60,000 members 
dedicated to protecting America's natural resources and to 
improving the quality of the human environment. NRDC has a 
longstanding interest in the efficient management of the U.S. 
Bureau of Reclamation's water projects and in protecting water 
quality. Thus NRDC has established a "Water Pricing Project" to 
analyze and propose a solution to the problems stemming from 
subsidized water projects in the West.^ The crisis at Kesterson 
is a vivid example of the costs associated with the unwise and 
uneconomic use of water resources. 

Over the past year NRDC has been active in the efforts to 
end the contamination of the ponds at the Kesterson Wildlife 
Refuge by toxic drainage water. We have argued that, as a matter 
of good public policy and the law, the drainage discharges into 
Kesterson must be discontinued and the toxic ponds cleaned. We 
are pleased to see that the flows of drainage into the Kesterson 
Reservoir are ending according to the schedule agreed upon by the 
Department of Interior and the Westlands Water District. Now the 



^ We are currently involved in a major study of the U.S. 
Bureau of Reclamation's water pricing policies and last year 
published the first volume of that study: E.P. LeVeen & L.B. 
King, Turning off the Tap on Federal Water Subsidies; Vol. I The 
Central Valley Project: the $3.5 Billion Giveaway . 



5-166 



Bureau's goal must be to clean up Kesterson as expeditiously as 
possible. 

The Bureau proposes to use a phased approach to the cleanup 
of Kesterson. The first phase will be the so-called "wet-flex" 
plan; if that plan fails, other plans, more likely to succeed, 
will be implemented. We have a nximber of concerns about this 
proposal. First, we believe that it does not satisfy the 
Bureau's legal obligations under the Migratory Bird Treaty Act or 
the State Water Board's Cleanup and Abatement order. In re 
Petition of Robert James Claus , Order No. WQ 85-1 at 34-35 (State 
Water Resources Control Board February 5, 1985) (hereinafter WQ 
85-1 or the Board's Order.) Second, we believe that the Bureau 
has not adequately defined or explained its proposed plan. 
Third, to the extent that the plan can be understood, we find 
that it rests to a disconcerting degree on a scientific theory 
about which there remains a great deal of uncertainty. Fourth, 
the plan fails to provide safeguards for the protection of 
wildlife, or to provide adequate mitigation for lost habitat at 
Kesterson. Fifth, the plan lacks the explicit decisionmaking 
criteria and opportunities for public review during its 
implementation that are essential under the open-ended approach 
proposed by the Bureau. 

The Bureau must provide a plan that will demonstrably clean 
up the Kesterson site completely by the February 1988 deadline 
established by the State Water Board, and must provide adequate 
mitigation for the loss of waterfowl habitat at Kesterson as soon 



5-167 



as possible. The program described in the DEIS does not achieve 
these goals. 

II. The Bureau's Preferred Alternative is Likely to Result in 
Continued Violations of the Migratory Bird Treaty Act 

Among the first signs of the magnitude of the problem at 
Kesterson were the extremely high rates of death and deformities 
of migratory birds, and later, their complete lack of success in 
nesting. The Secretary of the Interior recognized not only the 
grave harm to wildlife, but also his duty to prevent such harm, 
when he ordered the closing of Kesterson to agricultural 
drainage. By the time the actual cleanup gets underway, almost 
two years will have elapsed since Secretary Hodel ordered an end 
to the drainage. In the meantime, migratory birds and other 
wildlife continue to be exposed to selenium, and bird deaths and 
deformities are still taking place^ — in continuing violation of 
the Migatory Bird Treaty Act. The cleanup alternative preferred 
by the Bureau offers no assurance that migratory birds will 
receive imminent protection from the hazardous conditions at 
Kesterson. It is therefore likely that takings of migratory 
birds will continue under the preferred alternative, in direct 
violation of the Migratory Bird Treaty Act. 

Migratory birds are afforded special status by international 
treaties and by statute. This international resource is 



2 "Kesterson refuge still plagued by bird deaths and 
deformities," The San Francisco Examiner . June 12, 1986 at D-8. 



5-168 



protected from any action, save those specifically allowed by 
regulation, that would cause the birds to be killed or captured. 
16 U.S.C. Sec. 703 et seq . It was concern over violations of the 
Migratory Bird Treaty Act that caused Secretary Hodel to call 
first for the closure of Kesterson, and then for the end of 
drainage discharges into Kesterson. And yet, despite the 
importance of the Act in the events leading up to the cleanup 
proposal described in the DEIS, nowhere does the document mention 
the Migratory Bird Treaty Act, nor the responsibilities incumbent 
on the Bureau under it. Perhaps the reason for this startling 
omission is that the Bureau wishes to avoid acknowledging that 
its preferred cleanup alternative is unlikely to bring an 
expeditious end to the takings of migratory birds. While the 
DEIS does not give an estimate of how long cleanup will require, 
it appears to us from a previously published schedule that, even 
with optimistic assumptions regarding response time of monitoring 
and planning, it might be five to ten more years before Kesterson 
is satisfactorily cleaned under the preferred alternative. ^ if 
such is the case, the EIS must so admit, and reconcile the 
preferred approach with the Bureau's responsibilities under the 
Migratory Bird Treaty Act. 



2 Timetable, Submission of the United States Department of 
the Interior, Bureau of Reclamation, Mid-Pacific Region, 
Sacramento to SWRCB Workshop, March 5, 1986. 



5-169 



III. The Bureau's Preferred Alternative Fails to Comply With the 
State Water Board's Order 

The lengthy process of the preferred alternative appears 

unlikely to comply with the February 1988 cleanup deadline 

established by the State Water Board. The Bureau appears to 

assume, incorrectly, that the Board's order does not require a 

full cleanup of Kesterson by 1988. The DEIS states that the 

Board's order requires, 

in part, [the Bureau] to either close Kesterson 
Reservoir to further discharges of drainwater, or to 
upgrade Kesterson Reservoir to meet requirements for a 
hazardous waste surface impoundment. 

(DEIS at 1-3) This incomplete statement ignores that under each 

of the alternative courses of action permitted the Bureau under 

the order, a com.pleted cleanup of the area is to be accomplished 

by February 1988: 

The Bureau shall achieve full compliance with this 
section no later than three years from the date of this 
order . . . . 

Appendix at 4 (emphasis added).* The Bureau's preferred 

alternative is unlikely to meet that deadline and therefore fails 

to comply with the Board's order. 

IV. The Bureau's Preferred Alternative Has Too Many 
Uncertainties 

Considerable uncertainty surrounds the "wet-flex" plan 

preferred by the Bureau, both as to the exact nature of the plan 



*It should be noted that this date was not arbitrarily 
chosen by the Board, but rather was mandated by state law. Cal, 
Health & Safety Code, § 25208. 



5-170 



itself and as to whether science supports its successful 
implementation. A major shortcoming of the DEIS is its failure 
to outline clearly the preferred alternative and its 
contingencies. The omission of both specific dates for plan 
evaluation and contamination criteria triggering new cleanup 
actions critically hampers our ability to comment on the cleanup 
plan. Meaningful comment on the preferred alternative is 
impossible when its most essential components are left to ad hoc 
decision-making at some future date. 

For example, although the DEIS notes the serious risk that 

10 the food chain may continue to be poisoned under the first phase 
"wet-flex" plan, the plan contains no provision for addressing 
squarely this serious problem. The plan suggests two alternative 
courses of action in the event that contamination continues: (1) 
reharvesting of contaminated vegetation, or (2) removal of 

11 sediments. But the plan fails to specify the criteria for 
determining what level of contamination should trigger such 
actions. Obviously, the definition of "contamination" is 
critical to how well the plan will protect wildlife, including 
migratory birds and endangered species. 

The scientific uncertainty associated with the cleanup 
approach preferred by the Bureau compounds the effect of the 
vagueness of the Bureau's plans. That uncertainty is 
particularly grave where the role of toxins in the food chain is 
concerned. In protecting wildlife, cutting off the pathways of 
selenium uptake in the food chain should be of the highest 



5-171 



priority. One of the more crucial scientific assumptions 

underlying the preferred alternative is that cattails and other 

plants in the Reservoir will not create aerobic conditions in thj 

12 rhizosphere that would enable the selenium to re-oxidize to 

selenate. But the research summarized in the DEIS supports the 

opposite conclusion. Nine scientific studies are cited 

documenting the oxidizing power of marsh plants in the normally 

reduced environment of salt-marsh muds.^ The DEIS summarizes, 

Even though selenium is present in reduced form in 
the Reservoir sediments, selenate from root oxidation 
probably occurs in the rhizosphere of the emergent 
marsh plants. The oxidizing power of cattails and 
other marsh emergent plants growing in reduced flooded 
sediments could result in a significant, measurable 
quantity of sediments being oxidized.^ 

Nonetheless the DEIS concludes, "Most of the reduced selenium ii 

the sediments is probably not oxidized further than elemental 

selenium by cattail roots." (DEIS p. 4F-11) This crucial 

premise of the preferred alternative is unsupported. 

The wet-flex plan contemplates leaving stalk-bottoms and the 

most contaminated parts of the plant material, the roots and 

rhizomes,^ in the ground, while spending $4 0,000 to remove the 

upper stems and leaves. Given the strong possibility that the 

stalks and roots will continue to attract animals, and the 



5 DEIS p. 4F-11, 

6 Id. 



"^ According to the DEIS at 3-9 the average concentration o^h 
selenium in the above-ground plant parts, dry-weight basis is ^M 
approximately 35 ppm, while the roots and rhizomes average 64 
ppm. 



5-172 



likelihood that whole plants will escape cutting (DEIS p. 4H- 
28) , we question the value of this procedure. These 

13 possibilities suggest a potentially serious continuing pathway 
into the food chain. Further, as the DEIS acknowledges, many 
plants are likely to re-establish themselves quickly in 
contaminated areas. (DEIS p. 3-18.) Under the chosen plan, such 

14 vegetation may eventually be harvested or chemically controlled, 
but the circumstances in which such action would be taken remain 
unclear. 

The impacts of continual re-harvesting of newly contaminated 
vegetation should also be evaluated. The DEIS mentions, but does 
not discuss, the use of herbicides as one method to control 
growth. If herbicides are to be used for this purpose, the FEIS 
must detail the plan for herbicide use, including areal extent, 

■'■^ type of chemical, and frequency of application. While the DEIS 
discusses the impacts of herbicide use on the air, climate and 
wildlife, it does so in a conclusory fashion, and neglects to 
mention entirely the impacts of such herbicide use to water and 
surrounding land, which may be significant as well. Because 
hazing is not effective for some species (DEIS p. 4H-9) , and 
because hazing in any event is not contemplated under the 

16 proposed plan, the impacts on wildlife of the contaminated plants 
between harvestings or herbicide applications may be significant. 
The DEIS ignores this possibility. 

In short, numerous uncertainties surround the Bureau's 
preferred cleanup plan, both regarding what steps the Bureau 

8 



5-173 



actually plans to take under various conditions and regarding how 
effective those actions will be. Because of the scientific 
uncertainties surrounding the wet-flex approach, we oppose its 
selection as the Bureau's preferred alternative. If the Bureau 
selects this approach nonetheless, it must, at a minimum, 
17 delineate the plan more clearly in the Final EIS, set up a firm 
cleanup schedule that will comply with the Board order, and 
establish criteria that will be used to determine when various 
contingency measures will be taken. Without such strict 
guidelines, the wet-flex plan is in danger of being hopelessly 
open-ended and the tragedy at Kesterson is likely to be prolonged 
indefinitely. 

V. The Bureau's Approach Does Not Provide Adequate Mitigation 

Under the Bureau's management, 1,283 acres of wetland 
habitat at Kesterson have been destroyed. While the Bureau 
appears optimistic that this habitat can be restored under its 
wet-flex approach, there is significant uncertainty in this 
18 regard, as we have noted above. The Bureau is therefore 

obligated to provide interim mitigation during the cleanup period 
and to commit to providing permanent mitigation in the future 
should the cleanup be unsuccessful. The DEIS does discuss 
potential mitigation measures, but it fails to pinpoint when and 
how, under the preferred alternative, the decision will occur 
whether to mitigate this temporary and/or permanent loss of 
wildlife habitat. Thus, not only has the Bureau failed to make a 



5-174 



commitment to mitigation, but it has neglected even to specify 
how it will decide what kind of mitigation program to undertake. 

We are additionally disturbed by the lack of discussion of 
the consequences of the Bureau's startling decision to choose, as 
potential mitigation sites, two areas where evidence suggests the 
existence of selenium contamination. Of one of the proposed 
sites, the DEIS states, "[W]ater quality of the Gallo property is 
best characterized by information on Salt Slough. No onsite 
monitoring has occurred." (DEIS p. 4E-10) This characterization 
gives us great concern. Salt Slough is not a clean environment: 
although the water there does not generally exceed the drinking 
water criterion for selenium, concentrations are at a level shown 
to be of concern to wildlife. According to the DEIS, Salt Slough 
selenium levels range from 1 to 13 parts per billion (ppb) (p. 
4E-10) , a level which is not low enough to provide sufficient 
protection for migratory birds or other wildlife. The DEIS 
itself states that selenium concentrations should be no more than 
2 to 5 ppb for the protection of wildlife (p. 4H-33) . This 
conclusion is supported by other field research.^ 

Another deficiency of the Bureau's proposed mitigation 
approach is that it fails to consider the difficulty of 
establishing wetland in upland areas. The DEIS states that the 
current use of the land at the offsite mitigation parcels is 
grazing or pasture land (p. 41-10) , and implies that parts of the 



^ Lemly, E cological Basis for Regulating Aquatic Emissions 
from the Power Industry; The Case with Selenium , 5 Regulatory 
Toxicology and Pharmacology 465 (1985) . 

10 



5-175 



parcels are upland (p. 4F-6) . The success of the mitigation 
effort may be determined by the choice of land parcels, but the 
20 DEIS does not evaluate these choices in terms of the likelihood 
of successful mitigation, nor does it specify what actions will 
be taken should they be unsuccessful. 

Of critical importance to the success of mitigation efforts 
in the area surrounding Kesterson is the provision of adequate 
supplies of good quality fresh water. It appears from the 
proposal in the DEIS that the Bureau has underestimated the close 
link between the vitality of a mitigation site and an adequate 

2.1 water supply. The DEIS puts off the critical questions of how to 
assure a permanent water supply to mitigation areas. Without a 
commitment from the Bureau to provide water, the proposed habitat 
mitigation has little value. 

The Final EIS should thoroughly consider the short- and 
long-term effects of using the Gallo and Wolfsen properties 
compared to other options, such as wetlands restoration under the 

22 onsite disposal option. Because of the paucity of information 
regarding the suitability of the proposed sites for wetlands 
habitat, site testing should be performed and the results 
included in the Final EIS before making a final site selection. 
In general, we believe that the Bureau's mitigation program needs 
a great deal mors development. 



1 



11 



5-176 



VI. The DEIS Must Discuss the Option of Treating the Wastes as 

Hazardous 

Thus far our comments have focused primarily on the 

deficiencies in the preferred alternative. A defect common to 

all of the plans considered is the assumption the sediments in 

the Kesterson ponds and the San Luis Drain may be classified as 

designated waste instead of as hazardous waste. The Bureau 

implicitly renews the argument it made before the State Water 

Resources Control Board that the "total threshold limit 

concentration" (TTLC) is the only measure of whether a substance 

is toxic hazardous waste. (DEIS pp. 3-8, 3-9) As the Board 

responded, 

This argument must be rejected for several reasons. 
First, the DOHS hazardous waste management regulations 
indicate that a waste will be considered hazardous if 
it meets the statutory definition even if its 
components do not exceed the specific concentration 
limits in Article 11.... WQ 85-1, at 34-35. 

The Board noted that the sediments had been measured at below the 

TTLC, but nonetheless went on to require treatment of the wastes 

as toxic hazardous wastes because of the demonstrable effects of 

the waste on the environment. Because the preferred alternative 

does not assure swift control of those effects, the Bureau should 

23 not assume that the wastes can be treated as designated wastes 

for the purposes of cleanup. 

The Bureau must furthermore consider the option of treating 

the sediments in the San Luis Drain as hazardous, even if the 

sediments at Kesterson are classified as designated waste. The 

concentrations of selenium in the Drain appear to be even higher 

12 



5-177 



23 



24 



than those in the Reservoir, ana Bureau selenium measurements 
indicate that the hazardous waste criterion Is exceeded "at 
I several locations along the drain. "9 

At the various hearings „e have attended, the Bureau has 
stressed the relative costs o. the di„ere„t alternatives, c.ten| 

in these comparisons of the various alternatives, the wet-nex^ 
approach always appears to great advantage because of its 
«:ativel. ic„ cost, oiven the importance the Bureau appears to' 
ace on costs, it is disturbing to find unexplained variations 
costs among the alternatives. These variations tend to 
dxstort the cost estimates in favor of the „et-fle. pi.n. 

ror example, all the alternatives but the „et-flex plan 

include a price •f-arr «•*>-,•., 

price tag of sxx .xllion dollars for replanting with 

appropriate vegetation, it is noted >, 

°^^'^' h°^ever, that, "This cost 
could be reduced substantial! v ■« ^ 

the Off •. . "^"^^-^iy if several years were allowed for 
the offsite mitigation wetland to establish « m . 
wet-flPv r.1 aoiish... In contrast, th( 

wet flex Plan seems to anticipate that the wetland deprivation 
could continue for years. <0.ls p. 3-ls, . .he state Water 



n 



v«c4. "*^* ^^Partment of Interior tt c « 

Kesterson Program Interior P^o^g^e^is^H^pcr^^r^," ti^l^^^li?' i , 



13 



5-178 



Board's order clearly requires mitigation, ^° and the Bureau 
should include that mitigation in all of the budgets. 

The distortion of cost estimates in favor of the preferred 
plan also appears in the choice of other components selected for 
each plan. For instance, the stated costs of the wet-flex plan 
optimistically assume that vegetation and groundwater removal 
will not have to continue, while the off site disposal plan 
includes not only groundwater extraction ($1.37 million) but also 
a reverse osmosis plant ($35.92 million) . Since it is still 
unclear that extraction wells will be necessary, even if offsite 
disposal is necessary, the Bureau should also construct a more 
flexible, less costly variation of the offsite disposal 
alternative. Such an alternative should also include a plan that 
takes cognizance of the relative segregation of the areas of 
highest selenium concentration in the Reservoir. Partial 
excavation might provide adequate cleanup while ameliorating the 
high cost of disposing all of the sediments in a Class II 
landfill. 

VIII. The DEIS Fails to Consider Possible Cumulative Impacts 

Another serious lack in the DEIS is the complete failure to 
consider the cumulative impacts of the chosen alternative on 
wildlife. These impacts may be significant, especially for 
endangered species. Many wild species have already been deprived 



lOwQ 85-1, Appendix (Cleanup and Abatement Order) Para. 3, at 
5. 

14 



5-179 



of adequate habitat for a number of years by the toxic drain- 
water stored at Kesterson Reservoir. The phased approach allows 
that deprivation to continue indefinitely. Furthermore, there is 
a serious risk that exposure of birds to pollutants will continue 
under the wet-flex and immobilization plans. 

The long-term effects of both the reduced habitat and 
potential continued selenium exposure under the wet-flex plan are 
not assessed in the DEIS. Although the DEIS devotes two 
sentences to short-term vs. long-term productivity, and lists 
some possible sources of cumulative impacts, it does not include 
the postponement of a commitment to mitigation as a potentially 
29 significant source of long-term impacts. The lack of habitat in 
the Pacific Flyway is already stressing many bird populations. 
The interaction of the Bureau's cleanup plan with these stresses 
is nowhere considered in the DEIS. 

IX. Conclusion 

The urgent nature of the need to cleanup Kesterson has 
required the rapid preparation of a cleanup plan. We commend the 
effort that the Bureau has made to develop a solution to the 
problem in such a short period of time. Unfortunately, we do not 
believe that the Bureau's preferred approach actually represents 
a solution. The plan appears to allow continued violation of 
federal law (the Migratory Bird Treaty Act) , and fails to comply 
with the State Board's order. Many important parts of the plan 
have been left too uncertain and will not, consequently, undergo 

15 



5-180 



the thorough public coiiunent demanded by the National 
Environmental Policy Act. The many scientific uncertainties 
about whether the Bureau's approach can succeed are compounded by 
the amorphous nature of the preferred alternative. To resolve 
this problem, we urge the Bureau to adopt explicit criteria with 
which to evaluate the success of each cleanup step, to establish 
a timeline under which the criteria will be applied and remedial 
actions taken, and to provide for public input in the process of 
criteria selection and other decisions throughout the actual 
cleanup. Furthermore, in light of the uncertainty about the 
possibility and timing of restoration of the Reservoir as 
wildlife habitat, we urge the Bureau to begin off site mitigation 
as soon as appropriate screening of sites can be accomplished. 



16 



5-181 



Response to Comments of the 
Natural Resources Defense Council 

1. The USER has taken into account the provisions of the 
Migratory Bird Treaty Act in developing its proposed action 
for the cleanup and closure of Kesterson Reservoir. The 
proposed action incorporates adequate safeguards to fulfill 
the user's responsibilities under this and other statutes 
intended to protect migratory birds or other fish and wild- 
life resources. It is the USBR's view, which is supported 
by advice from the Department of Justice, that the Migra- 
tory Bird Treaty Act does not proscribe the activities of 
federal officials who carry out their statutory respon- 
sibilities with due care and in good faith, even though the 
activities might result in incidental bird deaths. 

In regard to the State Board's order, a CPMP will be devel- 
oped on the basis of the EIS and submitted to the State 
Board for its review and approval before implementation. 

2. The Final EIS more fully describes the proposed action. 

3. See discussion of FRP risks in Chapter 3 of this Final EIS. 
The proposed action includes a nuisance abatement program 
to reduce risks to wildlife, and discusses alternative 
measures that could mitigate for lost habitat values. 

4. The Final EIS more fully describes the monitoring program 
and decision criteria that are part of the proposed action. 
Monitoring results will be available to the public. 

5. In regard to the SWRCE ' s order, see response to comment 1 
above. In regard to mitigation for loss of waterfowl 
habitat at Kesterson, both the Draft and Final EIS identify 
and discuss alternative mitigation actions. 

6. Please see the response to comment 1, above. 

7. The proposed action description in this Final EIS discusses 
time frames under the phased approach. Please see response 
to comment 1 regarding Migratory Bird Treaty Act 
compliance . 

8. The USER'S interpretation of WQ 85-1 is that the February 
1988 date represents the time by which a cleanup plan must 
be implemented, not the time by which cleanup must be 
completed. 

• 

9. The Final EIS more fully describes the proposed action, 
including the monitoring program and the decision criteria. 

10. The USBR's proposed action includes monitoring of the food 
chain as described in this Final EIS. If monitoring indi- 
cates the FRP will be unsuccessful in achieving selenium 

5-182 



reduction growth in biota, either the Immobilization Plan 
or the Onsite Disposal Plan would be implemented. 

11. Please see the response to comment 10. 

12. The Draft EIS recognizes there is a risk that marsh plants 
will oxidize the sediments and mobilize selenium, but does 
not conclude that this risk will cause the FRP to fail. 
Additional LBL research, and monitoring after plan imple- 
mentation, will determine whether oxidation of sediments by 
plant roots will result in unacceptable levels of food 
chain contamination. 

13. Under the FRP, as described in this Final EIS, vegetation 
will no longer be harvested in the wet ponds. Biological 
monitoring after plan implementation will determine the 
rate at which the above-ground selenium concentration of 
vegetation will be reduced due to the introduction of 
selenium-free water. 

14. The Final EIS more fully describes the vegetation manage- 
ment and monitoring programs along with decision criteria. 

15. Under the proposed action, herbicide application is not 
planned. 

16. The USER anticipates continued hazing of wildlife at 
Kesterson Reservoir under the FRP until cleanup goals have 
been achieved. Although herbicides and vegetation 
harvesting are discussed in the Draft EIS, these measures 
are not part of the proposed action; vegetation will be 
controlled by discing (northern dry ponds) and flooding 
(southern wet ponds) . 

17. The proposed action description contained in this Final EIS 
provides additional detail regarding the phased approach, 
schedules, and decision criteria. 

18. The proposed action description in this Final EIS describes 
the mitigation actions being considered by the USER, and 
remaining issues that must be researched in selecting 
appropriate actions. 

19. The Draft EIS discussion of surface water quality on the 
Gallo property was, regrettably, somewhat misleading. The 
parcel being considered for offsite mitigation is only a 
small portion of the 5,450-acre Gallo property. Salt 
Slough does not run through the portion of the Gallo prop- 
erty being considered for offsite mitigation; therefore, 
this portion of the property is not affected by selenium 
loads in Salt Slough. 

20. Since the completion of the Draft EIS, extensive wildlife 
and botanical surveys have been conductd at the Gallo and 

5-183 



V7olfsen properties, both of which have been proposed as 
offsite mitigation areas. Although both these properties 
have been degraded by plowing and overgrazing, they occupy 
lowland areas that have high potential for the creation of 
wetland habitats. The Gallo and Wolfsen properties are 
ideally suited for water management due to existing ag- 
ricultural canals and drainage systems. Only the highly 
disturbed soils of these properties have been proposed for 
wetland enhancement; native grasslands and vernal pools on 
the southern Gallo property already have high habitat value 
and would be maintained in their current state with reduced 
grazing pressure. 

21. Water supply alternatives for potential offsite mitigation 
wetlands are identified in both the Draft and Final EIS. 

22. The Gallo and Wolfsen properties were selected by the USFWS 
as potential offsite mitigation sites because they have a 
high potential for habitat management for wildlife pur- 
poses, and because they had previously been identified by 
USFWS as having priority for acquisitions or for conser- 
vation easements (Draft EIS p. 1-14). The USER is unaware 
of any facts indicating that these sites would be unsuit- 
able for wetland habitat development. 

23. In arriving at its assumption that the sediments would be 
classified as designated waste, USER considered not only 
TTLC, but also the other definitions of hazardous waste 
contained in Section 2522 of Subchapter 15. The Draft EIS 
recognizes the possibility that the SWRCB could classify 
the sediments as hazardous waste in describing the Offsite 
Disposal Plan (p. 3-41); this plan could easily be modi- 
fied, should the sediments be classified as hazardous 
waste, through disposal of the sediments in a Class I 
rather than a Class II landfill. 

24. This Final EIS recognizes wetland habitat impacts of the 
FRP, and presents alternatives that could mitigate these 
impacts. 

25. This Final EIS more fully describes the proposed action. 
In determining the cost of the FRP, it was assumed there 
will be no groundwater or vegetation contamination and 
therefore no cost of cleanup. Components of alternatives 
can be rearranged as appropriate. 

26. The proposed action contains provisions for implementing a 
groundwater extraction program. Treatment of extracted 
water is not anticipated. This Final EIS provides a more 
thorough description of the proposed action. 

27. The Final EIS description of the proposed action includes 
partial excavation with onsite disposal. No acceptable 
Class II offsite landfill has been identified. 

5-184 



28. The wildlife impact analysis in the Draft EIS recognizes 
the effects of past contamination of Kesterson Reservoir on 
wildlife species using the Reservoir. The comment does not 
identify other specific past, present, or reasonably fore- 
seeable future actions which could add to the effects of 
the Kesterson Program and create significant cumulative 
wildlife impacts. The USBR's proposed action is not 
expected to result in a long-term continuation of wildlife 
contamination at Kesterson Reservoir. 

29. The USER is implementing alternative habitat development 
projects recommended by USFWS, and considering short- and 
long-term mitigation, as described in the proposed action 
description • contained in this Final EIS. 

30. This Final EIS more fully describes the proposed action 
which includes a monitoring program, timeline, decision 
criteria, and public involvement. 

31. See responses to comments 22 and 23. 



5-185 



-_ :_xp€rienccd in Government 

-.^ministration o( 
"jblic and Private Projects 
iiiective in Procunng Permits and 
_i,xhausting Administrative Process 
- _Jy<iensive Knowledge of 
•jovemment 

Regulations and Selective 
.inforcemeni Procedures 



imnrr 



RED TAPE ABATEMENT, LTD. 

P.O. Box 60291, Sacramento. CA 958600291 
Telephone Number (916) 348-2020 

Friday, June 27, 1986 



• Background in Resoujrce 
Management Air anu: Water 
Quality Standards 

• Water Rights and De'velopment 

• Hazardous Matenab Regulation, 
Disposal and Abatermcnt 

• Aggregate Mining Ort>erations 

• Land Use and Envncnnmental 
impact Analy-sis 



David Houston, Regional Director 
United States Bureua of Reclamation 
2800 Cottage Way 
Sacramento, CA 95825 

RE : COvMENTS TO "IHE KESTERSON PROGRAM DRAFT ENVIRONMENTAL IMPACT STATEMENT 

Dear Sir: 

RED TAPE ABATEMENT (RTA) had the opportunity to review the contents of 
the information contained in the United States Bureau of Reclamation. ' s 
(USBR's) Draft Environmental Impact Statement (DEIS) for Kesterson 
Reservoir and the San Luis Drain, and submits the following comments 
and recommendations. 

GENERAL STATEMENT: 

From a pure physical standpoint the report is impressive, and leaves no 
doubt that a great deal of time, energy and money went into its prepar- 
ation. However, despite its shear mass, weight and volume the text of 
the document is very general, lacks critical information, and complelely 
fails to address and or remedy the issue of paramount importance; nam^iely 
a solution to the long-term problem of salt deposition. 

Generally, it is customary for RTA to address specific issues raised in 
reports such as the DEIS, however, in this case, it will be consistent 
with the text of the report and only provide general comments. RTA wrill 
provide specific recommendations for eliminating further salt deposiitiop 
problems and treaths to water quality and wildlife. 

The DEIS provides the following alternative plans to "clean-up" the 
Rerservoir : 

• FLEXIBLE RESPONSE PLAN (vegetation harvesting, maintaining 
the ponds wet or dry, and monitoring); 

• IMMOBILIZATION PLAN (using water or soil cover to immobilize 
selenium in the Reservoir sediments); 

• ONSITE DISPOSAL PLAN (onsite disposal of contaminated sediments 
and vegetation, and creating upland habitat on the majority of 
the Reservoir) ; 

• OFFSITE DISPOSAL PLAN (offsite disposal of contaminated sediments 
and vegetation, and creating upland habitat on the majority of 
the Reservoir. 

It is also the Bureau's position that it intends to take a phased approach 
in its implementation of this program. 



5-186 



RE: COMMENTS TO KESTERSON PROGRAM DEIS 
2-2-2-2-2-2 

Despite the fact that the plans included in the DEIS include complemen- 
tary alternatives for the San Luis Drain (SLD) and potential offsite 
mitigation for loss of Kesterson wetland habitat, it: 

• Fails to provide an environmentally sound or ecologically feasible 
(short or long-term) solution for the disposal of drainage water 
from either the Westlands Water District (WWD) or any other area 
of the San Joaquin Valley (SJV) . 

• Only symptomatically addresses the biological and chemical feasi- 
bility of its alternatives, and fails to clearly state that even 
short-term positive effects, if any, are highly dependent on the 
implementation of all the alternatives. 

• Fails to exemplify the fact that there are presently no agri- 
cultural waste water discharge requirements in effect for agri- 
cultural drain water. 

• Fails to adequately address the bioaccumulative impacts of the 
potentially hazardous biocides that may be present in the Reser- 
voir and SLD, but have not been tested for. 

• Fails to adequately address the issue of synergism and' how this 
factor can impede any effective waste water monitoring program. 

• Makes constant reference to WWD water contractors conducting 
their own waste water monitoring program, which the success or 
failure is contingent on the old "Boy Scouts Oath of Honor". 

Although the phased approched is admirable it leaves to many unanswered 
questions, and raises additional uncertainties about the plans feasi- 
bility, effectiveness and timeliness for its implementation. In essence 
the phased approach only buys the Bureau, its' contractors, and the 
State of California more time, additional delays, and more expenditures 
of taxpayers money; for a salt problem that was not only recognized 
decades ago, but was perpetrated by your agency, its' contractors and 
the State of California. 

It is important to note, that each of you were fully cognizant of the 
fact that these lands should never have been irrigated until adequate 
drainage facilities were constructed and financed. 

For example, in 1960 Congress authorized the Secretary of the Interior 
(SOI) to construct the San Luis Unit of the federal Central Valley Pro- 
ject (CVP) . The original purpose of the construction project was to 
furnish water for the irrigation of approximately 500,000 acres of land 
in Merced, Fresno and Kings counties. "The act authorized construction 
provided, however, the construction of the San Luis Unit would not com- 
mence until the SOI had either received assurances from the State of 
California that it would make provisions for a master drain outlet and 
disposal channel for the San Joaquin Valley, or the Secretary made pro- 
visions for constructing a San Luis Interceptor drain to the Delta." 

The State subsequently determined not to participate in construction of 
the SLD, it opted to build its own master drain, which it also failed 
to do. Consequently, after the authorization of the San Luis Unit, the 
Bureau made plans to construct a drain which would extend 208 miles frcm 
Kettleman City in the southern SJV north to a discharge point in the 

5-187 



RE: COMMENTS ON KESTERSON PROGRAM DEIS 

3-3-3-3-3 j 

Delta at Suisun Bay. Between 1968 and 1975, 85 miles of the drainage 
system, known as the SLD, and the first stage of Kesterson Reservoir, 
a regulatory reservoir, were constructed by the Bureau; construction j 
was halted in 1975 due to funding limitations! ' 

However, in 1976, the Bureau came up with money and started con- 
struction of the subsurface drainage collector system that now serves 
42,000 acres in WWDI The Bureau initiated this action to continue 
agricultural operation at economically desirable levels of producti- , 
vity, the practice of installing subsurface drains to collect and I 
carry excess water and salts away for disposal thus evolved ! 

The construction of the SLD was terminated primarily because WWD con- I 
tractors complained they could not afford its costs — not for environ^ 
mental reasons — which occurred during economically properous times. 
In view of the aforementioned facts the last thing the Bureau should i 
have done was to build the subsurface drains; because this action onlyj 
compounded the ultimate salt deposition crisis. 

The Bureau, its' contractors, and the State's failure to construct the 
depserately needed drainage facilities were in direct conflict with 
federal and state mandates. Failure to construct drainage facilities 
in effect perpetrated the inevitable crisis confronting the SJV today,! 
and defies the legislative intent of the California Water Plan. J 

Depsite the fact that a plethora of studies have been done on the salti 
problems of the SJV, numerous committees have come and gone, decades j 
of water monitoring programs, and millions of dollars spent attempting 
to resolve this age old problem; there is no concrete evidence to sug- 
gest that government is any closer now to developing or implementing a 
solution to California's most complex water problem — salt deposition. 

How can we realistically expect farmers (CVP water contractors) to pay! 
for the cost involved in implementing any of the alternative plans, ori 
for a non existant drainage system, when they could not finance a speci 
fied drainage facility during economically properous time, when today 
agricultural is economically depressed? 

In addition to the economic crisis facing agriculture the CVP is alreac 
over burden with existing financial troubles that amounts to billions 
of dollars in deficits, which will ultimately be absorbed by the tax- ' 
payers. Can we afford to throw more money down the drain in view of tl 
aforementioned uncertainties? 

RECOMMENDATIONS: 

In view of the aforementioned information, and in the absence of a 
"specified drianage pain" RTA reluctantly makes the following recanmendai 

• Immediately discontinue water deliveries to all known problem 
lands within the WWD. * 

• Inventory all lands with the WWD and the CVP service area to 
determine whether they pose a similar salt-water quality pro- 
blem, and develop a plan to systematically phase-out irrigation' 
of these lands- 

5-188 j 



RE: COMMENTS ON KESTERSON PROGRAM DEIS 
4-4-4-4-4 

RECOMMENDATIONS CONTINUED: 

• Cease irrigation of any land service by the CVP that poses a 
treath to either water quality or fish and wildlife resources. 

• Conduct a cost-benfit analysis to determine whether it is 
economically feasible or justified to continue irrigating 
lands in the CVP service area. 

• Develop a plan to exchange or sell CVP water to other lands 
either in the service area, or to land outside the service 
area that do not pose similar water quality and or wildlife 
treaths. This action will require Congressional approval. 

• Cease any further allocation of public funds either to sub- 
sidize water deliveries or additional studies to abate the 
salt problems. 

6. Develop a cost-sharing plan to compell agriculturalist, CVP 
contractors, landowners, and investing firms in the CVP ser- 
vice area to pay their fair share for the cost to develop an 
effective drainage program to resolve the problems which they 
created. 

• Develop a plan to condemn and purchase all lands within the 
CVP service area that are know problem areas. 

• Take remedial actions forthwith to systematically abate the 
biological and -.chemical problems treathening the waters and 
resources of the State. 

• Stop playing politics and start doing doing your job. 

In conclusion it is only fair that your agency should recognize that it 
is the primary cause of the problem, because it failed (along with the 
water contractors and the State) to develop and maintain a policy to 
effectively deal with salt drainage problems, depsite the fact it is 
under a mandate to do so. However, all of these entities have reaped 
the fruit of the land. 

Failure to take responsibility for your actions, and to allow this pro- 
blem to go unabated, constitutes a violations of your duties and is in 
direct conflict with the public trust doctrine. 

Thank you for allowing bur firm the opportunity to comment on the DEIS. 
Respectfully, 




Patrick Porgans 

Resource Management Consultant 

PP:sp 

cc: State Water Resources Control Board 
-: Secretary of Interior 
Secretary of Resources 
California Department of Water Resources 

Media 

5-189 



Response to Comments of the Red Tape Abatement, Ltd, 

1. Issues of Westlands Water District and San Joaquin Valley 
drainwater disposal are beyond the scope of this EIS. 
Chapter 2 of the Draft EIS describes current programs 
designed to address such issues including: the San Joaquin 
Valley Drainage Program, Westlands Water District Drain- 
water Management Planning, the USER Contingency Plugging 
Program, and the Grassland Water District Interim Drainage 
Projects and' Long-Term Water Management Plan. 

2. The Final EIS proposed action specifies monitoring criteria 
and decision points to evaluate the effectiveness of the 
phased approach. 

3. The SWRCB and RWQCB, pursuant to WQ 85-1, are currently in 
the process of establishing quantitative water quality 
objectives for San Joaquin Valley surface waters receiving 
agricultural drainwater discharges. 

4. Kesterson Reservoir sediments have been analyzed for the 
toxic and bioaccumulative organic substances listed in 
Title 22 of the California Administrative Code. No levels 
were greater than the level of detection. 

5. The Final EIS describes the monitoring program for the 
proposed action. In addition to water quality, the moni- 
toring program addresses the effects of a number of impor- 
tant food chain items in the Kesterson Reservoir biota. 
The purpose of the monitoring program is to identify 
impacts that may be difficult to predict. 

6. Monitoring for the Kesterson Reservoir cleanup action will 
be conducted by the USER or its designees. The USFWS will 
have the option of performing biota monitoring for the 
Kesterson Program. 

7. The USER recognizes the commenter's concerns about resource 
management within the CVP ' s service area and the State of 
California. These issues are beyond the scope of this EIS. 



5-190 



SIER 
CAL 




LUB 

NIA 



6014 COLLEGE AVENUE, OA 



IFORNIA 94618 (415) 658 






June 30, ]986 



Ms. Susan Hoffman 
Kesterson Program Manager 
U.S. Bureau of Reclamation 
2800 Cottage Way 
Sacramento, CA 95825 

Dear Ms. Hoffman: 

Enclosed are the comments of the Sierra Club on the Draft Environme^j^al Impact 
Statement (DEIS) for the Kesterson Program. While we are pleased that the USER 
is proceeding to develop a clean-up program for Kesterson Reservoir, we do not 
endorse either the "Wet Flex" plan as the preferred alternative or the phased 
approach which the USER is taking in its clean-up actions. Our comments also 
reflect a number of other concerns we have with the DEIS and the proposed actions. 

Any response should be directed to the following: 



Mr. Ron Stork 
P.O. Box 186 
Mariposa, CA 95338 
Phone: (209)-742-7197 

Dr. Donald F. Anthrop 
46 Senior Avenue 
Berkeley, CA 94708 
Phone: (415) -841-4443 

Dr. Alvin Greenberg 
105 Wilson Way 
Larkspur, CA 94939 
Phone: (415)-924-6563 



Tehepite Chapter 
P.O. Box 5396 
Fresno, CA 93755 



Mr. David Nesmith 
Bay Chapter 
6014 College Avenue 
Oakland, CA 94618 
Phone: (415)-658-7106 



Thank you for your consideration of our views on this important matter. 

Youraf very sincerely. 



luraf very sincerely, 
maid F. Anthrop 



Donald F. Anthrop 
NCRCC Water Committee 



Mr. David Houston, Director, USBR 

Laura King, NRDC 

Ron Stork, Sierra Club 

Alvin Greenberg, Sierra Club 



5-191 



2410 BEVERLY BLVD., LOS ANGELES, CA 90057 1228 N ST. SACRAMENTO, CA 95814 530 BUSH ST. SAN FRANCISCO, CA 94108 



COMMENTS 

ON THE 

KESTERSON PROGRAM DRAFT ENVIRONMENTAL IMPACT STATEMENT 



submitted by 



THE SIERRA CLUB 



jm^ 25, 1986 



5-192 



After reviewing the Draft Environmental Impact Statement (DEIS) on the 
Kesterson Program, the Sierra Club wishes to express some major concerns with 
the DEIS itself and with the proposed course of action. 

The DEIS does not set forth any criteria for what constitutes acceptable 

or unacceptable levels of contamination. In a discussion of the Flexible Response 

Plan on page 3-18, for example, the following statement appears: 

"If the new vegetative growth and animal life were unacceptably con- 
taminated after a certain number of years, however, this plan would 
be considered unsuccessful, and it may be necessary to change to 
another plan." 

Nowhere, however, does the DEIS spell out the criteria by which any one of 
the alternatives will be judged to have failed to meet the clean-up objectives. 
Neither does it say who is to make that determination. Both of these are very 
serious flaws. The Sierra Club firmly believes the USBR should not be permitted 
to establish such criteria. Such criteria should be set either by the U.S. Fish 
and Wildlife Service (US F & WS) or by an independent body such as the National 
Research Council. 

From statements in the DEIS and from the timetable of the LBL research which 

is being conducted in support of the Wet Flex Plan, it would appear that the 

USBR does not intent to comply with State Water Resources Control Board (SWRCB) 

clean-up deadline of February 1988. The USBR is required to submit its plan 

for the clean-up of Kesterson Reservoir to the SWRCB by December 1, 1986. However, 

the following paragraph appears on page 3-16 of the DEIS: 

"Depending on the result of monitoring programs, it may be necessary 
to change to another plan if contamination is not being prevented or 
contained. For purposes of the analysis in this EIS, no definite 
duration of the plan is specified. The plan could, however, easily 
be modified to terminate if monitoring showed unacceptable con- 
tamination after a certain number of years." 



5-193 



-2- 

The one-acre test plot that LBL has established In pond 5 Is not at all 
representative of the entire reservoir, and research is only scheduled to begin 
in July. Thus, a decision on implementation of the Wet Flex Plan will have to 
be made on the basis of data from one-third of a biological year. The LBL group 
admits that little information is likely to be gained from this site until the 
next biological year. Any delays In complying with the SWRCB Order WQ 85-1 (as 
amended by Order WQ 85-5) are unacceptable to the Sierra Club. It is the view 
of the Sierra Club that the Final EIS must be rewritten so that decisions are 
made on a time scale to comply with the SWRCB clean-up deadline of February 1988. 

The Sierra Club believes that both the wet and dry options of the Flexible 
Response Plan will fail to achieve the stated objectives. Consequently, these 
alternatives should be discarded, the ongoing LBL research which is being con- 
dieted to support the Plan should be terminated, and the USBR should turn its 
attention to environmentally acceptable ways to cleaning up Kesterson Reservoir 
and establishing wetland habitat. 

In the DEIS, the USBR makes no distinction between the southern ponds which 
are essentially permanent water (ponds 1-4 and part of pond 5) and the more 
northern ponds (6 - 12) which are seasonal ponds (wet in the winter and spring; 
dry or mostly dry in the summer and autumn). The DEIS asserts that under the Wet 
Flex option, the ponds will be maintained as shallow ponds. It makes no distinction 
between the existing permanent water ponds and the northern six or seven seasonal 
ponds. This is important because whereas the southern permanent water ponds con- 
tain primarily two types of ve5;etatlon--cattails and algae--the northern ponds 
contain a wide variety of plants and invertebrates on which all types of wildlife 
feed. These seasonal ponds have far greater bird use than the permanent water ponds. 
Furthermore virtually all of the nesting of avocets, stilts, and cinnamon teal 
occurs on the dry areas of these ponds. In early spring of each year, these 



5-194 



-3- 



shallow ponds, which are generally less than 18 Inches deep, support large popula- 
tions of Invertebrates on which migrating waterfowl, particularly pintail, mallard 
and gadwall feed prior to their migration to the breeding grounds. If the ponds 
(especially the northern seven ponds) are maintained as shallow pond8(le8S than 
18 inches deep with numerous land islands, feathered edges to the water, and dry 
lands surrounding the water areas) wethink it is unlikely the ponds can be main- 
tained in an anaerobic condition during the entire year. Whether they can or not 
may be largely irrelevant since the presence of rooted vegetation in this environ- 
ment will almost certainly put selenium in the food chain. 

If water depth is increased to about four fett to eliminete rooted vegetation 
and most Invertebrates from Che food chain. It may be possible to immodllize 
the selenism, but the habitat will have been destroyed in the process. The low 
cost of the "Wet Flex" option compared to other alternatives is predicated on 
the assumption that the ponds are restored to wetland habitat and that offsite 
mitigation is not necessary. 

In a recent letter to tne Sierra Club Yodeler . the LBL group made the 
following statements: 

"Present plans involve maintaining the six wettest ponds under water, in 
some cases establishing a new, higher water level. Increasing water depth 
should keep out most wading and many dabbling birds, which would be 
most likely to ingest selenium cantaminated sediment. 

"The remaining six drier ponds will be allowed to dry out. This does 
not represent much of a change, as the dry northern ponds have 
historically received much less drain water, and most have flooded 
only in the winter, only in part, with rain water and groundwater 
that percolates up from the soil when nearby gun club owned fields 
are flooded." 

Since the DEIS makes no mention of allowing the northern ponds to dry out 
under the Wet Flex option, the statement by the LBL group raises some troubling 
questions : 

1) If the northern ponds could, in fact, be completely and permanently 
dried out, the habitat (which is the most valuable habitat on Kesterson 

5-195 



-4- 



10 



11 



Reservoir) would be lost. 

2) Since these ponds cannot be kept dry all winter, the very thing that the 
LBL group says it wants to avoid will obviously happen--the selenium in the 
sediment will oxidize and become water soluble selenite or selenate ions when 
the ponds become wet in the winter months. 

To clean up Resterson Reservoir in an environmentally sound manner and 
establish a clean and healthy wetland habitat, it may be possible to dry out the 
ponds, remove the sediment and either haul it to an offsite disposal facility or 
store it on the existing Kesterson Reservoir in a lined and covered state-of-the- 
art engineered disposal facility, bring new soil into the ponds, and restore the 
wetland habitat using CVP water. It will also be necessary to remove the sediment 
from the San Luis drain so that it can be used to convey CVP water. Whether such 
a strategy will effectively achieve the clean-up of Kesterson Reservoir and the 
restoration of the wetland habitat depends on a number of factors including 
whether the ponds are completely dry before sediment removal is undertaken, the 
depth of selenium contamination of the sediment, the remaining depth of the clay 
layer in the ponds, the ability of scraper operators to remove the pond sediments 
without penetrating the underlying clay, and the degree to which selenium has 
penetrated the levees. The Sierra Club is not aware of any data concerning 
selenium penetration into the levees. This information is essential. If selenium 
penetration into the levees is significant or if any of the factors listed above 
result in selenium contamination of the reestablished wetland, it will be necessary^ 
to remove the sediment from the ponds, regrade the reservoir to its approximate 
original contour so that it drains into Mud Slough, import new soil, and reestablisi 
the original upland habitat. In this case, 1280 acres of wetland habitat will have, 
to be developed at a nearby offsite location as mitigation for the loss of the 
ponds . 

It is the position of the Sierra Club that the USER should immediately 
develop some wetland habitat on Kesterson National Wildlife Refuge or at a nearby 



5-196 



-5- 

offslte location to compensate for the temporary loss of the habitat on the 
Reservoir. Since birds are being hazed off the Reservoir, the 1280 acres of 
^^ ponds are and have been lost as wetland habitat since the autumn of 1984. Several 
more years will be required to restore wetland habitat on the ponds at Kesterson 
Reservoir or establish new wetlands at an offsite location. The continued loss 
of this habitat is unacceptable. 



5-197 



Response to Comments of the Sierra Club 

1. The Final EIS contains a description of the USBR's proposed 
action which is more detailed than the description con- 
tained in the Draft EIS. This Final EIS specifies decision 
points and criteria for contaminant levels. 

2. This Final EIS describes the monitoring program that will 
be implemented as part of the proposed action. Criteria 
for judging the success of the phased approach were devel- 
oped considering the input of USFWS and other agencies. 

3. USBR's interpretation of WQ 85-1 is that the February 1988 
date represents the date by which implementation of a 
cleanup plan must be initiated, and not the date by which 
implementation must be complete. USER intends to initiate 
implementation of the proposed action in March 1987. USER 
believes that this approach is consistent with the provis- 
ions of WQ 85-1, as amended by WQ 85-5. 

4. As discussed in the response to comment 3, the USER intends 
to comply with the deadlines established by WQ 85-1. As 
part of the biological monitoring program, long-term data 
on contamination in several habitat types will be obtained 
and used to determine the effectiveness of the FRP. 

5. See discussion of FRP risks in Chapter 3 of this Final EIS. 

6. This comment correctly points out the distinct ecological 
differences between the southern ponds (Ponds 1-5, and 7) 
which were permanently wet historically, and the northern 
ponds (Ponds 6, 8-12) which were only seasonally wet. The 
USER recognizes these differences in its proposed FRP — 
the northern ponds would remain dry (with some seasonal 
ponding in winter) and the southern ponds would be wet. 

The seasonal wetlands in the northern ponds attract large 
numbers of waterbirds and other wildlife. Under the FRP, 
these areas will be kept dry, made as sterile as possible 
by discing, and monitored. Hazing will be continued 
throughout Kesterson Reservoir until selenium concentration 
goals are achieved. If monitoring shows that this treat- 
ment of the north ponds will not be successful in achieving 
selenium reduction goals, additional management techniques 
or the Onsite Disposal Plan will be implemented. 

7. The proposed action, as described in this Final EIS, takes 
into consideration that the FRP will result in reduced 
habitat values, and describes measures under consideration 
that could mitigate for these lost habitat values. 

8. The Draft EIS evaluates two options for the FRP, wet and 
dry. The USER has combined these options into a single 
plan in its proposed action, which calls for keeping the 
southern ponds wet and the northern ponds dry. The USER 

5-198 



believes that the Draft EIS adequately assesses the impacts 
of its proposed action in the Draft EIS evaluation of the 
FRP wet and dry options. For example, it recognizes lost 
wetland habitat values under the dry option (Draft EIS 
p. 4H-27) . 

9. Although selenium leaching will occur in the northern pond 
seasonal wetlands, adverse effects on beneficial uses of 
surface or groundwater are not expected. The groundwater 
monitoring program will be conducted in the northern ponds, 
and if contaminant threshold levels are exceeded, a correc- 
tive action program will be implemented. 

10. The USER appreciates the Sierra Club's recommendations. 
Under the proposed action's Onsite Disposal Plan, re- 
creation of a wetland at Kesterson Reservoir through water 
application is not being pursued because of concerns re- 
garding residual contamination following excavation. 

11. The USER is implementing alternative habitat development 
recommendations of USFWS to mitigate for the effects of 
ongoing contamination. 



5-199 



David R. Dawdy. — Comments on Kesterson DEIS 



David R. Dawdy 

Consulting Hydrologist 

3055 23rd Avenue 

San Francisco, California 94132 

June 11, 1986 

U. S. Bureau of Reclamation 
Mid-Pacific Region 
2800 Cottage Way 
Sacramento, California 95825 

Re: DEIS Kesterson Program in compliance with NEPA 

To: U. S. Bureau of Reclamation, lead agency 

Page 4D-2. --Lateral Ground water Flow 

A major problem concerning Kesterson Reservoir is its effect 
on the ground water system. Some quick computations can be made 
based upon the physical system at Kesterson. All flow from 
Kesterson Reservoir is vertical. There are 1,280 acres in 
the Kesterson ponds. For each foot of vertical movement, 1,280 
acre-feet of water and solutes move into the ground water system. 
The inflow of drain water to Kesterson Reservoir is about 7,000 
acre-feet per year, which is about 5.5 feet of water per year 
over the ponds. Much of that evaporates, but the selenium and 
other solutes stay in the remaining water and go into the ground 
water. The Bureau of Reclamation estimates that about 60% of the 
inflow infiltrates into the shallow ground water. 

A mass balance should give the rate of vertical movement. 
Acre-feet of inflow minus acre-feet of evaporation less any 
increase in storage gives net seepage to ground water. Divided 
by the 1,280 acres of ponds will yield the average vertical 
velocity. That will determine the size of the problem. Where 
the problem water moves and how fast is one of the matters of 
concern. There is considerable water seeping out of the ground 
in the vicinity of Kesterson and traveling to Salt Slough and the 
San Joaquin as surface flow. Those surface flows should be 
monitored and estimated to obtain how much of the seepage to 
ground water is remaining to contaminate the local aquifer and 
how much is being exported to the surface flow system to be 
cycled to Southern California. The division of net seepage out 
of the ponds into accretion to the aquifer which moves toward 
Salt Slough as ground water and surface water effluent which is 
rapidly recycled into the system is critical to an understanding 
of what are present problems and future problems. 

A mass balance approach will give the magnitude of the 
problem in terms of the amount of pollution of the local aquifer. 
All of these analyses assume that all seepage goes to the local 
aquifer, only. If there is connection with the regional aquifer, 
the problem is more serious. Whether there is connection can be 
determined only by chemical analysis of the regional aquifer. 
The connection of the shallow and deeper aquifers is not 
mentioned in the DEIS. 

5-200 



David R. Dawdy. — Conunents on Kesterson DEIS 2 

Page 4D-2. — Velocity of groundwater movement 

Page 4A-2. — Surficial Clay thickness 

Figure 4-3.--Preconstr uct ion thickness of surficial clayey 

material at Kesterson Reservoir. 

The "preconstruction" thickness of the surface clay layers 
in Kesterson Reservoir was mapped in 1968 by the Bureau of 
Reclamation, and those areas with more than eight feet of clay 
cap were identified as potential borrow material sites for 
construction of the berms around Kesterson Reservoir. That map 
is shown as Figure 4-3 in the Draft EIS. Eleven such areas with 
a surface area of 9,406,800 square feet were identified, and they 
were to be excavated to a depth of three feet to obtain 1,045,200 
cubic yards of material for berm construction. 

However, preconstruction conditions have little or no 
bearing on the movement of water from Kesterson into the aquifer. 
Rather, postconstruction conditions are required. These are 
available, and should have been used in addition to or in place 
of Figure 4-3. An aerial photograph provided by the Bureau of 
Reclamation (BR-KRS-4-10 ) made 1-31-1985 has evidence of bull- 
dozer marks where borrow material actually was removed. Nothing 
could be identified in ponds 2 through 5 because of the water 
level in the ponds, but ponds 1 and 6 through 12 could be 
studied. The distribution of area proposed for borrow material 
versus that actually used is shown on Table 1. 

Pond Planned Area Cumulative Actual Area Cumulative 

Site-*- Area Site^ Area 

12 A 876,000 1,2 1,487,500 

11 - 876,000 3,4,5 1,650,000 3,137,500 

9,10 B 1,022,400 1,899,000 6,7,8 1,346,250 4,473,750 

7 C 686,700 2,585,700 9,10 582,500 5,056,250 



1 
2 



6 D 2,673,000 5,258,700 11,12,13 360,000 5,416,250 
1 K 394,200 5,652,900 14 490,000 5,906,250 

Sites identified in Figure 4-3 of the FIS. 

Sites identified in the aerial photo (BR-KRS-4-10) 



Table 1. — Comparison of proposed borrow areas with actual borrow 
areas used for berm construction at Kesterson Reservoir. 




5-201 



David R. Dawdy. — Comments on Kesterson DEIS 



Borrow 
Area 

1 

2 

3 

4 

5 

6 

7 

8 

9 
10 
11 
12 
13 
14 



Area Removed from 
0-2 2-5 



Indicated Depth 
5-8 >8 



of Clay Layer in Feet 



150,000 


60,000 


15,000 











510,000 

235,000 

825,000 

75,000 

325,000 

105,000 













200,000 



60,000 

127,500 

165,000 



290,000 

60 ,000 

75,000 

565,000 

100,000 

382,500 

85,000 

50,000 

100,000 

90,000 



640,000 













201,250 

100,000 



40, 000 

50,000 

35,000 

200,^00 



Total 225,000 2,275,000 2,150,000 1,266,250 
Percent 3.8 38.45 36.35 21.4 

Table 2. — Distribution of clay cap within actual borrow areas. 

The effect of the change in choice of borrow areas has an 
effect on potential infiltration from Kesterson Reservoir. The 
potential borrow areas were chosen on the basis that they had 
more than eight feet of clay cap. If one attempts to remove | 
three feet of clay from an area with three feet or less of clay, ^ 
the underlying sand is exposed, and infiltration is accelerated. 
As is shown by Table 2, some 40 percent of the borrow areas had | 
the clay cap almost or completely removed. Thus, some 85 acres j 
of added area in the Kesterson Reservoir area have no clay cap. 
This is in addition to any area of natural exposure of sands. 

The infiltration and ground water movement will be 
controlled by the areas without clay cap. Assuming a vertical 
permeability of 10 feet per day of infiltration rate for the sand 
and 0.1 foot per day for the clay cap (Luthin, June 8, 1966, page 
13), the relative rates of vertical seepage into the shallow 
groundwater table would be: 



Area Without 
Clay Cap 
(Acres) 

85 
150 
200 



Potential for 
Seepage in Area 
Without Clay Cap 
(Acre- feet/day) 

850 
1500 
2000 



Potential for 
Seepage in Area 
With Clay Cap Ratio 
(Acre- feet/day) 

120 7.1 

113 13.3 

108 18.5 



Thus, the area with little or no clay cap controls the 
seepage into the shallow ground water. There is sufficient 
potential for seepage from those areas without a clay cap to 
supply all the seepage possible, for about 60% of the 7,000 acre 
feet of inflow infiltrates into the shallow ground water. The 
clay cap in Kesterson Reservoir, therefore, is not a constraint 



5-202 



David R. Dawdy. — Comments on Kesterson DEIS 



on movement of water into the aquifer. It is infiltrating at the 
rate at which it flows away from Kesterson in the surrounding 
aquifer system. If one is to make a mathematical model of the 
flow system, that model must include an assessment of the areas 
without clay cap. Their location within the ponds will determine 
the length of the flow paths, the head drop, and the velocity of 
ground water movement. A "micro-model" of the ground water 
system is necessary to understand its response. If such a model 
is not constructed, a very simple mass-balance model will give an 
estimate of the flow system as good as an over-generalized model 
which describes the true system only in an "average" sense. 

For example, let us make a very simple-minded mass balance 
analysis. Assume all water moves toward Salt Slough, 6000' from 
Kesterson Ponds. The ponds are two miles long. The area between 
is about 2.25 square miles, or 1500 acres in round numbers. 



Aquifer 


Water 


Time 


to Fill 


Time 


to Fill 


Thickness 


Content 


3000 


acf t/yr 


4500 


acft/yr 


50' 


20' 


10 


years 


7 


years 


100' 


40' 


20 


years 


13 


years 



The seepage water is either rising as artesian water or 
moving at rates of 1' per day or both. If three years of seepage 
have gone into the ground water, it has displaced at least 1/7 of 
the water in the shallow aquifer and, thus, has moved a minimum 
of 900' for about 0.8 foot a day. In the 'worst' case, it has 
displaced 3/7 of the water, and is moving about 2.3 feet a day. 
The correct answer probably lies somewhere between, and some (if 
not most) of the seepage has appeared as artesian flow. 

An alternative way to compute the velocity of the ground 
water movement in the vicinity of Kesterson through the relation 
of the mass balance viewpoint is to relate the thickness of the 
shallow aquifer to the velocity of the ground water flow which 
corresponds with that thickness. What goes into the ground water 
aquifer as infiltration from the Kesterson Ponds is what must 
move through the shallow aquifer system. Thus, a mass balance 
approach is "Volume in is equal to volume out". 



Volume of Infiltration = Length of Periphery of Kesterson 

X Distance Travelled by the Ground Water 
X Thickness of the Shallow Aquifer 
X Porosity of the Shallow Aquifer 

Let us further assume that the volume of infiltration is 
4,000 acre feet per year, based on the Bureau of Reclamation 
statement that 60 percent of the inflow percolates. A quick 
analysis of potential evapotranspi ration on a monthly basis 
combined with a steady inflow of the seepage indicates that the 
4,000 acre feet is a fairly good estimate for the amount of 
infiltration into the shallow aquifer. The porosity of the 
shallow aquifer can be assumed to be about 0.4. That is, 60 
percent of the aquifer is composed of the matrix of sands and 
clays, whereas 40 percent is composed of pore spaces for the 
water to move through. Porosity varies from 0.3 to 0.4 for sand, 

5-203 



Veloc] 


ity 


ft/yr 


1.7 


o 


6.8 


o 


10 




94 


L 


125 


MP 


188 


L 



David R. Dawdy. — Comments on Kesterson DEIS 5 

from 0.4 to 0.5 for silt, and from 0.45 to 0.55 for clay. The 
average value for the shallow aquifer probably is close to 0.4. 
The periphery of Kesterson Reservoir is about 8.8 miles. With 
those values given, the velocity of ground water movement can be 
directly related to the thickness of the shallow aquifer. 

Thickness = 4 ,000 acf t/yr X 43560 sq ft/acre 

0.4 X 8.8 miles X 5280 ft/mile X velocity 

Thickness in feet = 9375 

Velocity in ft/yr 

The results of this relation are shown as follows: 

Thickness of Shallow Aquifer 
feet 

5,500 o 

1,380 o 

937.5 

100 L 

75 MP 

50 L 

where "o" denotes the official value for velocity often quoted by 
the Bureau in the past, "L" is the estimate of aquifer thickness 
cited in the Luthin report, and "MP" is a most probable value for 
thickness. 

All values shown above are conservative estimates of the 
velocity of the water in the shallow aquifer. The porosity value 
probably is close to correct. The ground water will 
preferentially move toward Salt Slough, however. The natural 
ground water gradient is toward the San Joaquin River. 
Therefore, the use of the total periphery of 8.8 miles is 
undoubtedly an overestimate, although dispersion should increase 
the effective width of the flow from Kesterson beyond that of 
only the length facing Salt Slough. A correction for a more 
precise modeling of that effective width of flow might increase 
the velocities by another 1/3 to 1/2. Thus, a simplified mass 
balance leads one to conclude that the movement of groundwater is 
probably somewhere around 125 to 300 feet per year, or 1/3 to 0.8 
foot per day. In that case, seeps 600 feet down gradient from 
Kesterson toward Salt Slough should start receiving water from 
Kesterson after about 2 to 5 years. These values are within the 
range of 50-1000 feet per year given on page 4D-2, and are 
probably more accurate. They depend on no assumptions concerning 
permeability, but only on the physical dimensions of the aquifer. 

In order for the "official" values for ground water velocity 
to hold, the shallow aquifer must be from 1000 to 5000 feet 
thick. If the "official" values were stated in those terms, they 
would not be accepted. The Luthin values for the thickness of 
the aquifer are reasonable, and those values place reasonable 
bounds on the velocity of movement of the ground water. 

There is an implicit assumption in most of the ground water 
analyses that none of the ground water will migrate to the 

5-204 



David R. Dawdy. — Comments on Kesterson DEIS 



surface. If there are any local surface contacts of stringers of 
higher permeability material, the average slope will be the 
distance to the point of surface discharge. If such a point is 
1,000 feet from the dikes, say, then the slope is 0.01, not 0.001 
and the velocity of the flow is multiplied 10-fold. If discharge 
is within 100 feet of the ponds, the velocity is 100-fold. 

Page 1-12. — Preliminary alternatives for the San Luis Drain 

A quick look at the argument presented above indicates that 
Kesterson is not the ultimate problem, but merely the present 
crisis. Westlands Water District obtains over 1,000,000 acre- 
feet of irrigation water a year. Assume that only 300,000 acre- 
feet of that goes to the shallow ground water table. 7,000 acre- 
feet are draining into Kesterson. Where are the other 293,000 
acre-feet? They are migrating downgradient, and will surface in 
the drain, or in Kesterson outside the ponds, or in the 
Grasslands, or will drain directly into the San Joaquin system. 
Plug the drain, and that volume of water is still going to 
surface somewhere. To handle all that water, the San Luis Drain 
would need to handle over 400 cfs of continuous flow. That is 
what is headed for it. Kesterson never would have handled that 
amount. The 7,000 acre-feet per year is not even the tip of the 
iceberg. It is one ice cube. 

A quick reconnaissance estimate of flows and their fate can 
be made without waiting for a long period of time. More data may 
increase the accuracy of present estimates, but answers now are 
more important than better answers later. As is indicated by the 
mass balance approach above, extensive, expensive, time-consuming 
studies may not give better answers, now or later. If one waits 
five years for the "best" answer, that answer may be irrelevant, 
and it may be wrong. The problem may be so out of control by 
then that any answer will be academic. 



'icwi'd /< ^cu^dj 



5-205 



David R. Dawdy. — Comments on Kesterson DEIS 



Selected Pertinent Citations: 

Luthin, James N., Final Report on Seepage from Reservoir Sites in 

the Dos Palos and Kesterson Areas Western Merced County, June 

8, 1966, Special Consultant Reports to California Department 
of Water Resources. 

page 13. --"Field measurements of the soil permeability and 
examination of the soil strata indicate that there is about five 
feet of surface soil underlain by at least 100 feet of sand. ..The 
vertical permeability of the surface soil was obtained from 
inf i Itrometer measurements and seems to be about 0.05 inches per 
hour, or 0.10 ft/day. The permeability of the sand underlying 
the surface soil is about five inches per hour, or 10 ft/day." 

Luthin, James N., Report on Expected Seepage into Salt Slough and 
the San Joaquin River from the Kesterson Enhancement Area 
Western Merced County, September 29, 1966, Special Consultant 
Report to California Department of Water Resources. 

page 19. --"A sample calculation indicates that the estimated 
seepage may be between one and two second-feet if the enhancement 
area is kept more than 2,000 feet from the sloughs and river, and 
depth of ponding does not exceed five feet." Note: One or two 
second feet would yield about 700 to 1400 acre-feet per year. A 
water balance by the Bureau of Reclamation indicates that 60% of 
the 7,000 acre-feet of inflow infiltrates, so that about 4,200 
acre-feet per year appear to be leaving the reservoir area as 
seepage. This indicates an average flow rate of about 4.5 cfs. 
Because some of the ponds are dry part of the time, the maximum 
rate of flow would appear to be greater than the average value of 
4.5 cfs. 

page 20. — "In the calculation of the seepage it was assumed that 
the surface soil layers are eight feet thick. It would be a 
gross error to use this eight feet as a basis for calculating 
borrow materials. Irregularities in the surface soil make it 
hazardous to assume any specific depth of borrow materials 
without additional field information. It appears likely that 
removing more than one foot of surface soil in many cases may 
result in a large increase in the infiltration rate since in most 
cases, the least permeable layer occurs one to three feet below 
the soil surface." 



5-206 



Response to Coimnents of David R. Dawdy 

1. The impacts of Kesterson Reservoir on groundwater are 
discussed in Section 4D of the Draft EIS. The connection 
between the shallow and deep aquifers was not discussed in 
the Draft EIS. A brief summary of that history is provided 
below. 

Historically, throughout most of the service area, the 
hydraulic gradient between the shallow and deep aquifers 
was upward across the Corcoran Clay. Before surface water 
became available for irrigation, however, average water 
level declines in excess of 100 feet reversed this upward 
gradient in portions of the service area (Hotchkiss and 
Balding 1971, and Miller et al. 1971). In the early 
19 50 's, imported surface water began replacing groundwater 
for irrigation and water levels stabilized or began to 
rise. Nevertheless, wells penetrating the deeper aquifers 
remain potential pathways for cross-contamination near 
Kesterson Reservoir. 

The uses located 48 wells within 2 miles of Kesterson 
Reservoir (Balding et al. 1969). Of these wells, 22 did 
not penetrate below the Corcoran Clay; 16 penetrated below 
the Corcoran Clay and were constructed with a gravel pack 
or tapped aquifers above and below the Corcoran; and con- 
struction data on 10 wells were not available (Ford 1984) . 

2. The USER agrees that the preconstruction clay thickness 
data are inadequate for developing a detailed picture of 
the interaction between the reservoir and groundwaters. 
However, these data were judged acceptable for evaluating 
the cleanup alternatives after: 1) LBL (1985a) compiled 
available well log data and concluded that the preconstruc- 
tion map represented existing conditions reasonably well, 
2) calculating the total volume of clay used to construct 
the levees, and 3) comparing the excavated areas on the 
post-construction 1-foot contour map with the preconstruc- 
tion clay thickness map. 

3. The USBR agrees that the potential for seepage from the 
sandy areas exceeds the estimated seepage and that the 
actual seepage is limited by the amount of water that can 
be transported through the underlying aquifer. 

4. The average linear groundwater velocity presented in the 
Draft EIS was from 50 to 1,000 feet/year. However, the 
mean value is 250 feet/year. Furthermore, in using a mass 
balance approach before site-specific permeability data 
were available, a velocity of 90 feet/year was calculated. 

Although these latter values are consistent with those 
calculated by the commenter, the range from 50 to 1,000 
feet/year better expresses the heterogeneity of the 



5-207 



underlying materials and, as such, is more reasonable for 
estimating the distance that contamination may have 
traveled. 

5. The USER agrees that the potential for surface seepage 
exists. In addition, the combined effect of the precipita- 
tion deficit and high groundwater levels probably result in 
significant groundwater losses to evapotranspiration. 

6. The USER shares the commenter's concerns about drainage 
problems in the San Joaquin Valley. However, issues of 
agricultural irrigation drainage within Westlands Water 
District are beyond the scope of this EIS. Chapter 2 of 
the Draft EIS describes current programs designed to ad- 
dress such issues including: the San Joaquin Valley Drain- 
age Program, Westlands Water District Drainwater Management 
Planning, and the USER Contingency Plugging Program. 

7. The USER generally agrees with these observations. 



5-208 



Doris Ostrander Dawdy 

Author and water quality researcher 

3055 23rd Avenue 

San Francisco, CA 94132 

May 6, 1986 



U. S. Bureau of Reclamation 
Mid-Pacific Region 
2800 Cottage Way 
Sacramento, CA 95825 



Re: DEIS/Kesterson Program/Comments in Compliance with NEPA 
To: U. S. Bureau of Reclamation, Lead Agency 

The Bureau has supplied a summary of selected events since 

(pp. i-ii) 
1958/when construction of Kesterson Reservoir in Merced County began. 

A few preliminary dates also need to be reviewed. 

The reservoir itself has a rather muddy origin, having been 

preceded by abandonment of a better site near South Dos Palos; by 

warnings of dire consequences to fish and wildlife habitats dependent 

upon water contaminated by irrigation drainage; and by a formidable 

obstacle in the way of the San Francisco Bay Region Water Quality 

in 1963 
Control Board. Following its warning/to the Bureau that the 

irrigation drainage destined eventually for the Sacramento-San 

Joaquin Delta probably would not be acceptable without pre-treatment, 

the Board issued on February 20, 1964, Resolution No. 535. The 

resolution prohibited the discharge from the proposed San Luis 

Drain for which Kesterson was a regulating reservoir until the 

discharger submitted evidence that the proposed discharge would not 

adversely and unreasonably affect the receiving waters for any 



5-209 



DEIS comments of Doris Ostrander Dawd> 
to Bureau of Reclamation/5/6/86/page 2 



of the beneficial uses being protected by the Board. 

Farmers expect cheap water. Separating out the pollutants 
with pretreatment is expensive and significantly adds to the costs 
of irrigating their lands. Most of Westlands' lands are in low 
return crops because the delicate, demanding high income crops 
cannot be grown on marginal soils. It was a matter of controversy 
at the start that marginal lands in San Joaquin Valley should not 
be irrigated. Initially it was boron that was of concern, a con- 
stituent that demands about twice as much water to free its insidious 

as 
effect on root systems of low/eft4 well as high income crops. Se- 

linium was known to be present in the Valley, but its insidious 
influence was not anticipated. The farmers pressed for a drainage 
system as early as 1955, and got it included in the San Luis Act 
of 1960 wherein it was anticipated that the state would collaborate 
with the Bureau in building a master drain. The state backed out 
in 1967. The Bureau, succumbing to pressure from Westlands, proceeded 
to purchase the Kesterson property in 1968, and to take adjacent 
properties by the power of eminent domain. The principal victims, 
along with the astronomical loss of waterfowl and the lesser loss of 
warmwater sport fish, are the ranchers adjacent to Kesterson. 

The first important shortcoming of the Bureau's DEIS is the 
absence in its bibliography (Chapter 9) of such relevant publications 
as the selenium studies of Geological Survey chemists Theresa Presser 
and Ivan Barnes, and the first report of Dr. James N. Luthin on 
seepage from the reservoir sites dated June 8, 1966. From the outset 
Kesterson was known to be a high risk site. 

5-210 



DEIS comments of Doris Ostrander Dawdy 
to the Bureau of Reclamation/5/6/86/ 3 



The second important shortcoming of the Bureau's DEIS is the 
inadequacy of its hydrology data (DEIS 4D-2). To facilitate the 
work of the Final EIS analysts, more complete data has been excerpted 
from the Bureau's Preliminary Draft EIS dated February 1986, pre- 
pared for the Bureau by CH2M Hill and Jones & Stokes Associates: 

Lateral Groundwater Flow . An estimate of the lateral 
groundwater velocity away from Kesterson Reservoir toward 
Salt Slough is 50 to 1,000 feet/year. This rate was cal- 
culated using Equation D-1, and data presented in Table 
D-1. The shallow aquifer permeability for this calculation 
is based on LBL single-well pumping test analyses (LBL 1985). 
The hydraulic gradient of -0.00225 ft/ft is based on a 
maximum normal water elevation in Kesterson Reservoir of 
78 feet and an elevation for Salt Slough roughly 7,100 feet 
to the northeast of 62 feet. The porosity range was arbi- 
trarily chosen to represent an unconsolidated sand. In 
general, this calculated groundwater velocity exceeds previous 
estimates because the site-specific permeability values cal- 
culated from the LBL pumping test data reflect the heterogeneity 
of the underlying strata due to the complex pattern of braided 
stream channel deposits. Dr. James Luthin used a permeability 
value of 10 feet/day in calculating seepage rates from the 
proposed reservoir for the DWR in 1966 (Luthin 1966). Addi- 
tional preconstruction hydrologic data have been summarized 
by the USBR (USBR 1967). 

Equation D-1 

v = - la 
n 

where v = average linear groundwater velocity (feet/day) 
K = permeability (feet/day) 
i = hydraulic gradient (feet/feet) 
n = effective porosity (fraction) 

Equation D-2 
pe = 16.9 Eh at 25° C 
Where pe = electron activity 

Eh = potential difference between two electrodes (volts) 



5-211 



DEIS comments of Doris Ostrander Dawdy 
to Bureau of Reclamation/5/6/86/page 4 



HYDROLOGIC DATA FOR THE GROUNDWATER VELOCITY CALCULATION 



Parameter 
Permeability of the Shallow Aquifer^ 

Porosity of the Shallow Aquifer 

Maximum Normal Water Elevation in 
Reservoir 

Elevation of Salt Slough^ 

Distance Between Kesterson Reservoir 
and Salt Slough 



Value 

26-310 ft/day 
(mean = 115 ft/day) 

0.25-0.50 



78 feet 
62 feet 

7,100 feet 



LBL. 1985. 



Freeze and Cherry, 1979. 
*^USBR, 1985. 



/// 



The attention of the Final EIS analysts is also called to earlier 
calculations which should have been noted in the Chapter 9 bibliog- 
raphy under "Personal Communications" (9-18). These were occasioned 
by the information on groundwater movement provided the California 

State Water Resources Control Board by the Bureau and may have par- 

up time period 
tially determined the clean' and abatement/ requirements of the Board's 

order WQ 85-1. The Bureau maintained then, and until recently has 
continued to maintain that the rate of groundwater movement in the 
Kesterson area ranged from 1.7 to 6.8 feet per year. At this author's 
request the Bureau supplied Aerial Photo BR-KRS-4-10 showing bull- 
dozed areas of the ponds not under water as of January 31, 1985. 
From that map David R. Dawdy, hydrologist, estimated groundwater 



5-212 



DE I R. comments of Doris Ostrander Dawdy 
to Bureau of Reclamation/5/6/86/page 5 



movement rates that coincide with those furnished a year later by 
the Bureau's DEIS consultants. Copies of Dawdy 's computations 
were supplied the various state and federal water agencies in 
Sacramento, and accepted as accurate by hydrologists in the 
Geological Survey. Hydrologists in the other agencies were not 
asked for their reactions. The margin of error between the 1.7 to 
6.8 feet per year and the 50 to 1,000 feet per year shows the 
need to examine carefully the alternatives the Bureau has proposed 
in the DEIS. 

The third important shortcoming of the DEIS is the absence of 
an alternative premised upon shutting off the water to lands that, 
in view of the present dilemmajin Merced County, should not be irrigated, 
The Bureau's projects since early times have contributed to surpluses 
of crops across the nation that have hurt farmers, and the subsidies 
that enabled them to survive are now being trimmed. California's 
per-farmer subsidies in 1982 were second highest in the nation- 
US, 700 according to a recent article in the Washington POST; the 
national average was $3,300. There are two attractive alternatives 
amonS the Bureau's four: a restored wetlands habitat and an uplands 
habitat. They are expensive. The wetlands habitat has the dis- 
advantage of having to accommodate the contaminated residue of the 
ponds and the drain in a landfill on the premises. The uplands 
habitat alternative anticipates its storage in another county. 



5-213 



DEIR comments of Doris Ostrander Dawdy 
to the Bureau of Reclamation/5/6/86/page 6 



7 
8 



On Jhe positive side, the Bureau and CH2M Hill have provided 
in the DEIS a representative cross-section of opinion from the 
residents of Merced County. The closer they are to Kesterson, the 
more anxious they are to have the contaminated residue moved out 
of the county. It did not originate there, but that does not 
mean that selenium and other contaminants are not moving through 
the soil toward the San Joaquin River via irrigation projects other 
than Westlands! They are a component of irrigation drainage, so 
the question arises as to what is the one best long-term alterna- 
tive and how can it best be implemented. To irrigate or not to 
irrigate certain lands must be dealt with in conjunction with 
the StateBoard's cleanup and abatement order and the Interior De- 
partment's closure order. 

wet method 

The shortcoming's of the Bureau's preferred/alternative are: 

It will not end the foul smell of the ponds, for its effect depends 
upon anaerobic conditions; it will not mitigate the waterlogging of 
adjacent properties; and if it doesn't work, the follow-up methods 
to comply with the above orders will bring the cost to about the 
same as the more expensive wetlands and upland habitat alternatives. 
It is not conceivable that Merced County residents will find either 
this preferred (by the Bureau) alternative, known as the Flexible 
Response Plan, or the Immobilization Plan acceptable. 

The author recommends Wetland Restoration with Offslte Disposal 
or the Upland Habitat Offsite Disposal Plan. 



Doris Ostrander Dawdy 



^.. 



./ 



7 



5-214 



(■:L'lf) 



DEIS comments of Doris Ostrander Dawdy 
to Bureau of Reclamation/5/6/86/page 7 



Addendum 

Re: BOR's preferred alternative - the "wet" option 

Recent data from the Fairchild test wells in Santa Clara 
County reveals that a thick layer of clay may not shield deep 
aquifers from contamination. Inasmuch as these findings in the 
May 4 issue of the San Jose Mercury-News are too recent to have 
been used in designing the preferred alternative, they are here 
referred to as an addendum. 

I have followed closely all reports issued by Lawrence Berkeley 
Laboratory's scientists assigned to Kesterson. At the outset 
the idea looked promising. However, some of the very safeguards 
LBL recommended (keeping the ponds wet and ascertaining the locations 
of stringers, windows, etc) were not supported by actions taken by 
the Bureau. Some of the ponds were allowed to dry out; prior data 
relating to clay thicknesses were supplied LBL, but it appears that 
it reflected conditions before bulldozing the ponds; public pro- 
nouncements by LBL were identical to those made by Bureau personnel 
notwithstanding data at hand that showed considerable groundwater 
movement from the ponds, particularly in a northeasterly direction. 
The Bureau and LBL, in their pronouncements, have left the public 
to wonder what all the furor is about if the movement is a mere 
1.7 to 6.8 feet per year instead of the 50 to 1,000 feet per year 
set forth in the DEIS to which this author is responding. 

In view of the recent discovery at Fairchild and adjacent 
industries, it would be hazardous indeed to proceed witjX-llTe pre- 
ferred alternative. 



5-215 




Response to Comments of Doris Ostrander Dawdy 

1. The work of Presser and Barnes and Luthin were evaluated in 
preparation of the Draft EIS. Luthin (1966) was included 
in the Draft EIS References section. Presser and Barnes 
(1984, 1985) have been added to the Final EIS bibliography 
(see errata sheet) . 

2. The equation and data used in calculating the average 
linear groundwater flow velocity is provided below for 
reference. 

^ _ Ki 
n 

where v = average linear groundwater velocity (feet/day) 
K = permeability (feet/day) 
i = hydraulic gradient (feet/ feet) 
n = effective porosity (fraction) 

The hydrogeologic data to evaluate this equation are listed 
in the following table. 



KESTERSON DATA 
Parameter Value 



Permeability of the shallow aquifer 26-310 feet/day 

(mean = 115 feet/day) 

Porosity of the shallow aquifer 0.25-0.50 

Maximum normal water elevation in 

Kesterson Reservoir 78 feet 

Elevation of Salt Slough 62 feet 

Distance between Kesterson Reservoir 

and Salt Slough 7,100 feet 



Sources: Freeze and Cherry (1979); LBL (1985a); USER (1985c) 



The average linear groundwater velocity presented in the 
Draft EIS was from 50 to 1,000 feet/year. However, the 
mean value is 250 feet/year. Furthermore, in using a mass 
balance approach before site-specific permeability data 
were available, a velocity of 90 feet/year was calculated. 

Although these latter values are consistent with those 
calculated by the commenter, the range from 50 to 1,000 
feet/year better expresses the heterogeneity of the under- 
lying materials and, as such, is more reasonable for 

5-216 



estimating the distance that contamination may have 
traveled. 

4. Issues of agricultural irrigation within Merced County are 
beyond the scope of this EIS. Chapter 2 of the Draft EIS 
describes current programs designed to address such issues 
including: the San Joaquin Valley Drainage Program, West- 
lands Water District Drainwater Management Planning, the 
USER Contingency Plugging Program, and the Grassland Water 
District Interim Drainage Projects and Long-Term Water 
Management Plan. 

5. General issues related to agricultural drainage within 
Merced County are beyond the scope of this EIS. Relevant 
programs investigating these issues are provided in the 
response to comment 4, above. 

6. Odors at Kesterson Reservoir occur mainly during summer 
when ponds dry out. Under the FRP the ponds that histor- 
ically have been wet will be kept wet year-round. The 
other ponds will have no applied water. 

7. USER possesses no evidence of significant waterlogging of 
adjacent properties due to Kesterson Reservoir operations, 
but will continue to bear this concern in mind when con- 
ducting its monitoring program. 

8. The USER recognizes that if the FRP does not work, the 
total cost may be greater than implementing another alter- 
native immediately. See discussion of FRP risks in 
Chapter 3 of this Final EIS. 



5-217 



6415 Reeent Street 
Oakland, California 9A618 
29 June 1986 



Kesterson Proerain Manager 
Bureau of Reclamation 
2800 Cottage Way 
Sacramento, CA 95825-1898 

Dear Program Manager: 

This letter offers comments upon the Draft Environmental Impact Statement 
for the Kesterson clean-up program. 

I am greatly fearful that the desire for a comparatively inexpensive 
solution to this catastrophic and unanticipated environmental disaster has 
led the Bureau to proceed on the basis of wishful thinking rather than 
established fact. 

It would seem that the proposed options have been formulated in disregard 
of the overwhelming evidence that the waters now contained in the Kesterson 
ponds, together with contaminants also contained therein, do move into the 
groundwater and then move toward the San Joaquin River far more rapidly 
than the Bureau's figures suggest. 

Hydrologist David Dawdy, formerly with the U.S. Geological Survey, pointed 
out at the symposium held March 15, 1986, in Berkeley, that Kesterson water 
is surfacing on the Freitas's ranch adjacent. He argued persuasively that 
this contaminated groundwater was moving quite rapidly toward the San 
Joaquin River. Unprecedented livestock illness and mortality on the 
Freitas ranch hve been widely reported in the media but, so far as I am 
aware, have gone uninvestigated by the government. Dawdy showed maps of 
areas identified for borrow pits in the Kesterson feasibility studies and 
compared these with a recent aerial photograph demonstrating that material 
was dug from other areas, where the clay layer supposedly sealing the 
bottom of the ponds was thereby broken through. That this had been the 
case was previously pointed out by Fresno soil scientist Eldred Bliss in 
testimony to tlie State l.'ater Resources Control Board early in 1985. Bliss 
said he had been "horrified" upon visiting the construction site to see 
violations of the recommendations in James Luthin's feasibility study from 
1966 and 1970 not to disturb the surface soils where the clay layer was 
thin. 

In addition, it is not at all clear how hazards to fish and wildlife would 
be eliminated by either the wet-flex or the nearly identical 
immobilization-pond alternatives. The DEIS admits as much. Ponds would 
remain that would attract wildlife even should the ponds "work" as hoped. 
Are we to embark upon hazing birds away forever, and in the realization 
that the hazing program has been of only quite limited efficacy and that 
selenium toxicity is moving up the food chain into terrestrial animals? 

It has been five years since the detection of danger signs at Kesterson. 

5-218 



Fish and wildlife have been exposed to this toxic threat too long already. 
This exposure should not be prolonged in order to experiment with untested 
and dubious "cleanup" schemes that seem clearly to leave attractions for 
wildlife in place. Mechanisms for assessing efficacy of these schemes and 
deciding further phasing or abandonment of methodology that is not working 
well are not clearly spelled out. This is likely to lead to even more 
prolonged exposure. 

The only currently known sure way to remove threats to fish and wildlife 
seems clearly to be removal and disposal elsewhere. 

As for mitigation, the Bureau could make a profound beginning merely by 
guaranteeing an annual supply of good water to state and federal wildlife 
areas in the San Joaquin Valley. It has yet to do so. 
Sincerely, 

Alice Q. Howard 



5-219 



Response to Comments of Alice Q. Howard 

1. The proposed options were formulated after evaluating the 
available data. 

2. The average linear groundwater velocity presented in the 
Draft EIS was from 50 to 1,000 feet/year. The mean value 
is 250 feet/year. This latter value is consistent with the 
values calculated by Mr. Dawdy; however, the range from 50 
to 1,000 feet/year better expresses the heterogeneity of 
the underlying materials and, as such, is more reasonable 
for estimating the distance that contamination may have 
traveled. 

3. The commenter states that the media reported livestock ill- 
ness and mortality on the Freitas Ranch, but the government 
did not investigate these occurrences. The California 
Department of Food and Agriculture did investigate levels 
of selenium in domestic animals raised in the vicinity of 
Kesterson Reservoir. At the time of the study (November- 
December 1984) , the Freitas Ranch cattle were grazing on 
lands outside of the San Joaquin Valley and were not avail- 
able for study. 

4. The preconstruction clay thickness data were used for eval- 
uating the remedial alternatives after: 1) LBL (1985a) 
compiled available well log data and concluded that the 
preconstruction map represented existing conditions rea- 
sonably well, 2) calculated the total volume of clay used 
to construct the levees> and 3) compared the excavated 
areas on the postconstruction 1-foot contour map with the 
preconstruction clay thickness map. 

5. The Draft EIS discusses risks and impacts from implemen- 
tation of each alternative. See Chapter 3 of this Final 
EIS for a discussion of FRP risks. 

6. The Final EIS specifies monitoring criteria and decision 
points for determining the effectiveness of each phase of 
the proposed action. 

7. See Chapter 3 of this Final EIS for a discussion of FRP 
risks . 

8. Possible alternative mitigation actions are discussed in 
the Draft EIS in the context of the Kesterson Program. 
Alternatives for providing water to mitigation lands are 
addressed in the Final EIS. The issues associated with 
annual supplies of water to state and federal wildlife 
areas in the San Joaquin Valley, as a whole, are beyond the 
scope of this EIS. 



5-220 



COMMENTS & ISSUES IDENTIFICATION SHEET <>^ ^ vS^^©-\e\ 

DRAFT ENVIRONMENTAL IMPACT STATEMENT (EIS) ^^ 
KESTERSON PROGRAM C^ v 

June 1986 \^ A-^j kC(^ 1X^0 

Please use this form for your conunents and suggestions on 
the environmental impacts, the plan, the alternatives, and 
the evaluation criteria. This information will be provided 
to the consultants for their use. Attach additional sheets 
if needed. 

LEAVE YOUR COMPLETED SHEET WITH THE STAFF TONIGHT. OR FOLD 
AND MAIL. THANK YOU. 

1. Comments and statement of your views, issues, or con- 
cerns: 

CP U3a2 O/^ v\o+ SUA£ (fl*VN^ Co't( I cOt)sJ^ 
Oi-\K OJ^^C^ 0+vv2^ Hr>vtL^ W^Py^ . 

^"^..^S^^ S.M'^ tO^rfe^ CT^-N Sii^^ji ^u^l^LM.r^p^A 

2. Background information on why this concern: MCXUtJk- ^t U, 

osqa^^ (h(^<:^. <^^^^ S<^tR'OL^^^}^^ 





3. Suggested changes or ideas on how the issue can be 
resolved: 

^JU<JL c^v ^-^^"^ CM^? u:)L&^ ^4 



5-221 



Response to Comments of Jeff Kerry 

The Final EIS describes the USBR's proposed action includ- 
ing monitoring criteria, decision points, and responsible 
entities , 

USER possesses no evidence of significant "salting up" of 
adjacent properties due to Kesterson Reservoir operations, 
but will continue to bear this concern in mind when con- 
ducting its monitoring program. The salt content of the 
applied water is expected to be approximately that of the 
regional groundwater and as a result is not expected to 
cause "saJ.ting up" of adjacent land. 



5-222 



May 5,1986 
Deoartraent of the Interior 

Bureau of Reclamation 
2800 Cottage way 
Sacramento, CA 95825-1898 

Subject Kesterson Program 
Clean up. 

After perusal of your April Fact Sheet 2 
the off site disposal of Contaminated soil, and Vegita- 
tionwould seem the best way to go with the solution to 
this situation. 

The J.nvironmental impact is not completely 
satisfactory with any of the solutions. This fact must 
continually remind us that once a pollution situation 
becomes an established fact there are no satisfactory 
ways to aleviate the problem. 

Some portion of the solution to this sit- 
uation must rebound to the public in that meeting the 
expense of any remedy cannot be touted off to the far- 
mers because local officials were lax in enforcement 
of regulations which had a bearing on the violations 
of laws applicable, were not enforced 

^ • 

It is my belief that a thorough investi- 
gation of the officials involved be made as soon as ■> 
possible and corrective action be taken in th upper c 
eschelons within the Bureau. I also believe that this 
should present an example to all concerned as to the 
responsibility of the people involved, to the people 
of this state and ^e nation. >/e have had to many 
cases Of negligence and insome cases (Shargea of bri- 
bery and malfesance have been made. 

You|-s sincere.!^ 

Ivan H. Roscoe : 
2405 Chomor Ct. 
Antioch, CA 94509 



5-223 



Response to Comments of Ivan H. Roscoe 

The USBR appreciates the commenter's interest. The USBR's 
proposed action is described in the Final EIS. 

Funding alternatives for cleanup costs are currently under 
investigation. The USBR is unaware of any specific exam- 
ples of malfeasance of local officials in enforcing appli- 
cable regulations. 

The issues raised in the comment are beyond the scope of 
this EIS. 



5-224 




4154 Si Soic^u^ 2^t. 
<PMU!BuiJi. Calif. 93953 

YOSEMITE NATURAL HISTORY ASSOCIATION p o box ms YOSEwrre national park ca «53e9 



5-225 



Response to Comments of Ferdinand S. Ruth 

1. Selenium removal was evaluated as part of the development 
of cleanup alternatives. Treatment options are described 
in Appendix I of the Draft EIS. 

2. Dr. Oswald's algal method is a water treatment method, and 
is not appropriate for cleanup of Kesterson Reservoir 
sediments and vegetation. 



5-226 



THE KESTERSON CRISIS 



Jan Whittington 
UCSC Undergraduate 
Environmental Studies 
June 11, 1986 



arc. Uu^lidvU+ftci 11^ Y^Ujw • 



5-227 



Uncertaintv e::ists regarding sa^e le/els of selenium. TDS. ana 

boron -for wildli-fe, "The current selenium standard as 75 ppb, 
but ...as a conservative approach, it is assumed that 2-5 ppb 
sel eni um is safe -for wildlife, . . . (and ) tox i c 1 evel s of boron 
have not been determined for wi 1 dl i f e, . . . (USBR 1986, dElS:Chp. 
4H, p. 36)." This uncertainty accentuates the lack of 
scientific evidence available for involvement in the cleanup 
process. 

Under the Offsite Disposal Plan all wetland habitat at 
Kestersor. Reservoir would be lost, as well as fisheries, but 
there would be offsite mitigation of wetl^-nds, and cor.tinued 
natural rising of groundwater for an additional 450 acres of 

80 

wetland would occur at Kesterson. Also, to insure the safety of 
the Reverse Osmosis F'lant brine ponds to wildlife, they should 
be: configured to be long, narrow, and deep to facilitate 
hazing; growth of vegetation around the pond should be 
suppressed; pond margins should be steep and sterile; and any 
courtship behavoir of bare ground nesting birds should be 
disturbed (USBR 1986, dEISlChp 4H) . 

11. CRITICISMS 

One point made strongly throughout the dEIS was the fact 
that much more research on selenium biogeochemi stry with 
reference to Kesterson ecosystems must be conducted to ensure 
biological containment of hazards. However, even if such 
re-search is carried out, I'm not sure that an alternative could 
be r e.--r ^€■■l:l which would satisfv both the Federal and State 
Go .■ernmcnts whiile insurina ssfti'tv for wildlife. This doubt 



5-228 



involves inherent problems in our governments' abilities to 
address ecological di3a:sters. especially those caused by to.tic 
pollution. Some aspects o-f these problems ArG visible in the 
Kesterson Program dEIS. Even though costs o-f alternatives 
weren't to be considered in the planning process, cost lists for 
each alternative were given in the dEIS, and the least expensive 
alternatives were chosen as initial mitigation measures. Also, 
adjectives used to describe the cleanup processes and tools for 
implementation in the dEIS included not only "efficient" and 
"beneficial," but also "cost-effective." This -suggests an 
underlying objective of "cost-benefit" analyses of 
implementation for each alternative, however overshadowed by the 
primary influence of time deadlines. It is true that time 
deadlines 3.re- necessary to enact the planning process as a 
whole, but constraints on the effectiveness of alternatives 
according to time could lead to inconsiderati on of long-term 
impacts. I considered the planning approach to the Kesterson 
Program to be weak in its initial mitigation measures, even if 
made so in order to satisfy time constraints. I especially 
didn't appreciate the consideration of te Flexible Response Plan 
Dry Option as a viable plan for a hazard to wildlife of this 
3 magnitude. This problem is exemplified by the potential impacts 
of this plan, including the fact that wildlife could be exposed 
to more selenium under this option than under the No Acton 
Alternative. 

For purposes of dealing with the problems of selenium 
poisoninq, I believe that the Kesterson Program should be more 
irtv'olved with the oriains of selenium, as well as the- current 

5-229 



problem location. F'erhaps with further e:<amination of past 
natural floodings of salts from the San Joaquin Valley, and of 
existing deposits within lands under cultivation, more secure 
long-term as well as short-term conclusions could be made about 
mechanisms and conditions required for selenium immobilization. 
Hopefully these aspects will be examined and utilized by the San 
Joaquin Valley Drainage Program to create more ecologically 
sustainable practices, or modify the San Luis Unit. And as far 
as overall to>;ins are concerned (especially boron, molybdenum 
and TDS) , I am absolutely dissatisfied with the impacts 
discussed for Kesterson (not to mention other areas such as the 
San Joaquin River, which may be experiencing wildlife population 
declines this very moment similar to the extermination of almost 
the entire Kesterson Reservoir Fisheries, which went on 
undetected). Impacts on wildlife from toxins other than selenium 
were apparently disregarded as unimportant, and this bias has 
consequentially channeled the direction of Kesterson studies for 
the past 5 years. The lack of scientific knowledge available 
and applied to the cleanup plans on other toxins is epitomized 
by the fact that toxic levels for wildlife of boron have not 
been determined, nor have drinking water standards. 

It IS disturbing to note that had the USFWS not taken the 
actions required to secure Kesterson as a National UJildlife 
Refuge, the poisoning of wildlife may have gone Undetected. Had 
this been so, studies of poisoning would not have had any 
m^t i vat 1 orii-l basis, the public would have remained uninformed, 
j-nd harsrdi would h^^vr persirted. unacknowledged. Thi= is a 
C''.fii(''io: I S'^QLierict- of es'f'Ots i r( to;'ic waste disasters, anci too iiior. y 

5-230 



times stMdies have been conducted, and -funding (however we.aki 
o-ftered only a-fter the problem has been magnified to the point 
o-f endangering public health, far beyond assistance -for 
wildlife. And sometimes even then the problems lie unresolved. 

These problems call for a recognition of larger overall 
attitudes involving the American capitalistic e:.ploi tati ve 
approach to Nature, and the subsequent havoc wreaked on the 
biosphere. Outlines for a more sustainable approach are just 
now being envisioned, both in small ways: in Lawrence Berkeley 
Lab's Immobilization Plan Pond Option low-tech response, lending 
itself to natural organisms' abilities to take up selenium, and 
in larger ways: in the International Union for the Conservation 
of Nature's World Conservation Strategy planning of resource 
conservation -for sustainable development. 

Regarding the measures proposed in the Kesterson Program 
dEIS, there Are changes possible which would decrease the 
selenium exposure to wildlife. I would recommend that all 
research continue, and all aspects of cost analyses be 
abandoned. The importance of this issue should not be 
underestimated, as the Kesterson Program should be the first in 
a series of cleanup solutions involving agricultural drainwater 
•as the primary polluting source. The following are other 
measures which should be implemented: 1) Removal of 

all SLD sediments, and drying of them in an enclosed facility 
before disposal immediately, 2) Use of potato harvesting 
(removal o-f roots as well as stems) instead of hay cropping to 
protect wildlife which forage on these plant parts, and this 
would call for revegetation which could be beneficial to 



5-231 



11 



12 



13 



wildli-fe, 3) Prevention o-f any herbicide use considering the 
lacJ o-f knowledge o-f ef-fects on wildli-fe and selenium 
trans-formation, and potential harm-ful impacts o-f incinerating 
sprayed vegetation, and 4) Development o-f wetland mitigation 
^Ojsites -for wildli-fe use during all phases o-f plan implementation. 
Also, -further studies could be conducted on boron and other 
toxins in wildli-fe, including how the elimination o-f plants 
which aren't tolerant o-f boron e-f-fects the overall nutritional 
supply to wildli-fe on the land. 

Dealing with the source o-f the problem i s o-f primary 
concern in this situoction. On the larger scale, agricultural 
practices in the San Joaquin Valley should be thoroughly 
examined -for sustainabi 1 i ty . Perhaps in some areas dry farming 
could be economical 1 ■/ -feasible. And as mentioned be-fore, the 
San Joaquin Valley Drainage Program may o-f-fer assistance to 
these problems, especially if limits on water supply in 
California are realized. 

And on the global scale, the adoption of attitudes utlicing 
social and ecological factors in planning and development is 
essential in order to preserve Earth's living resources. Living 
resource conservation, according to the VJorld Conservation 
Strategy, is, "...positive, embracing preservation, maintenance, 
sustainable utilization, restoration and enhancement of the 
natural environment," and has three specific objectives, "...to 
maintain essential ecological processes and life-support 
systems. ... to preserve genetic diversity,... and to ensure the 
SL'stainable utilisation of species and ecosystems". It is my 
hope that the proposals implemented at K.esterson incorporate 



5-232 



13 



these attitudes, ensuring the safety of the San Joaquin kit io:: 
and other endangered plant and animal species at all costs, and 
providing a pathway -for other restoration proposals for 
sustainable agricultural practices and the preservation of 
wetland habitat. 



5-233 



Response to Comments of Jan Whittington 

1. Cost-effectiveness is a factor being considered by the USER 
in its comparison of alternatives. "Cost-benefit" analysis 
implies that each factor being considered is assigned an 
economic component, and a decision reached is based on the 
sum of such components. Cost-benefit analysis is not being 
utilized by the USER in evaluating Kesterson Program alter- 
natives. The USER believes that many of the factors that 
it must consider cannot be accurately assessed by purely 
economic criteria. 

2. Mitigation measures are described in further detail in the 
proposed action description contained in this Final EIS. 

3. The USER has rejected the FRP dry option for use throughout 
Kesterson Reservoir. A modified dry option approach will 
be used only in the northern ponds as described for the 
Proposed Action in the Final EIS. Potential hazards to 
wildlife will be reduced through a nuisance abatement 
program and monitored after plan implementation. 

4. Extensive research into the origin and extent of selenium 
contamination throughout the San Joaquin Valley is beyond 
the scope of this EIS. The USER is sponsoring additional 
research into these issues as part of the San Joaquin 
Valley Drainage Program. 

5. Wildlife deaths and deformities at Kesterson Reservoir have 
been linked to selenium contamination. No data are avail- 
able indicating that these wildlife problems are caused by 
constituents other than selenium. 

6. This Final EIS describes the continuing research program 
which the USER proposes. 

7. This Final EIS describes potential uses of the SLD under 
the proposed action. Water would be added to the SLD so 
that selenium is immobilized, and risks to wildlife or 
public health reduced. 

8. This Final EIS describes treatment of vegetation at Kester- 
son Reservoir under the proposed action. 

9. The USER appreciates the commenter's input on this issue. 
Incineration of vegetation to which herbicides have been 
applied is not part of the proposed action. Monitoring of 
vegetation and other biota will occur as described in this 
Final EIS. 

10. This Final EIS describes measures under consideration which 
could mitigate for lost wetland habitat values. 



5-234 



11. Monitoring of vegetation and other biota will occur as 
described in this Final EIS. 

12. Research on agricultural practices throughout the San 
Joaquin Valley is beyond the scope of this EIS. 

13. The USER generally agrees with these goals. 



5-235 



Response to Public Hearing Comments 

Summary of Public Hearings 

Public hearings on the Draft EIS were held at 7 p.m. in Los 
Bancs, Fresno, and Gustine, California, on June 17, 18, and 19, 
1986, respectively. 

The hearings were conducted by Larry Hancock, Assistant 

Director of the Mid-Pacific Region of USER. He was assisted by 

Susan Hoffman (Kesterson Program Manager, USER) , Alan Solbert 

(Environmental Specialist, USER) , and Charles Houghton (Planning 

Coordinator, USFWS) . 

Each of the three hearings were conducted in the same 
manner. Larry Hancock described the history of the problem, the 
regulatory response, the alternatives for cleanup, the proposed 
action, and the purpose of the hearing. He explained that the 
record would remain open through June 30, 1986, for receipt of 
written comments. Then, those attending were invited to present 
testimony, followed by a question-and-answer session. 

The following is a summary of the persons in attendance and 
the issues raised at the hearings. A complete transcript and 
record of attendance is on file in the office of the Kesterson 
Program Manager (MP-405) , USER, Mid-Pacific Region. 

Los Eanos Hearing . Attendance at the hearing totaled 34. 
The persons presenting testimony were: 

o Gail Pellerin for Assemblyman Rusty Areias 

o Dan Chapin, California Waterfowl Association 

o Jeff Kerry 

o Janette Freitas 

o Pat McNally, Merced Sun Star 

o Lloyd Carter, Fresno Eee 

Fresno Hearing . Attendance at the hearing totalled 33. 
The persons presenting testimony were: 

o Jerry Eoren, Fresno County Public Works and Development 
Services Department 

o Steven Hall, Land Preservation Association 

o J, Martin Winton, Flyway Grasslands 

o Doug Deary 

5-236 



Gustine Hearings . Attendance at the hearing totaled 24. 
The persons presenting testimony were: 

o Al Gorman, Merced County Board of Supervisors 

o Donald Anthrop, Professor of Environmental Studies, San 
Jose State College 

o David Witter, City of Los Banos 

o William R. Johnston, Westlands Water District 

o Janette Freitas 

o Roy Anderson 

Issues Raised in Testimony 

1. Mitigate all socioeconomic impacts. (Gail Pellerin, 
Los Banos) 

2. Expand summary to make EIS more understandable to lay 
people. (Dan Chapin, Los Banos) 

3. Specify what kind of monitoring will be done to ensure 
that wet flex is working. (Gail Pellerin, Los Banos) 

4. Specify what kind of criteria will be used to deter- 
mine if wet flex is. working. (Jerry Boren, Fresno; J. 
Martin Winton, Fresno; Donald Anthrop, Gustine) 

5. Specify who will decide if wet flex is working. (Dan 
Chapin, Los Banos; J. Martin Winton, Fresno; Donald 
Anthrop, Gustine) 

6. Consider the effect of discing the ground after remov- 
ing the vegetation. (Dan Chapin, Los Banos) 

7. Consider using the SLD to convey CVP water to the 
mitigation wetlands. (Dan Chapin, Los Banos; Donald 
Anthrop, Gustine) 

8. The Draft EIS does not describe long-range impacts, 
especially water quality impacts on the region beyond 
the immediate vicinity. (Jerry Boren, Fresno) 

9. The No-Action Alternative in the Kesterson Draft EIS 
is not consistent with the No-Action Alternative in 
the Draft EIS on Westlands Water District Drainage 
Disposal. The alternative and its impacts (e.g., 
economics) should be the same. (Jerry Boren, Fresno) 



5-237 



10. The impacts of ponding saltwater versus freshwater 
need to be evaluated. (J. Martin Winton, Fresno) 

11. Timelines for implementation of the alternatives are 
overly optimistic and cannot meet the February 5, 
1988, cleanup deadline because further environmental 
documentation and permitting would be required. (Jerry 
Boren, Fresno) 

12. Discuss who will pay for the proposal and the source 
of funding. (Gail Pellerin, Los Bancs; Jerry Boren, 
Fresno; J. Martin Winton, Fresno; Roy Anderson, 
Gustine) 

13. The northern ponds differ from the southern ponds, 
hydrologically and biologically. If kept wet, the 
biologically diverse northern ponds cannot maintain 
anaerobic sediment conditions because of rooted vege- 
tation. If the vegetation is removed, the wetlands 
values are lost. This would require replacement of 
wetlands — which is not proposed. (Donald Anthrop, 
Gustine) 

14. If the ponds could be totally dried, wetland values 
would be lost. Since they cannot be kept dry, seleni- 
um will oxidize and enter the water in winter. (Donald 
Anthrop, Gustine) 

15. It appears that the Bureau does not intend to comply 
with the February 5, 1988 cleanup deadline, since 
monitoring to determine if wet flex is working would 
continue for years beyond that date. (Donald Anthrop, 
Gustine) 

16. The USER should immediately begin mitigating the loss 
of wetland values that has already occurred. (Donald 
Anthrop, Gustine) 



Issues Raised as Questions 

17. If you fill the ponds with saltwater, will this affect 
adjacent lands? (Jeff Kerry, Los Bancs; Jerry Boren, 
Fresno) 

18. What is the USFWS position on wet flex? (Pat McNally, 
Los Bancs) 

19. The possibility of keeping some ponds wet and some dry 
was not explained in the Draft EIS. (Dan Chapan, Los 
Banos) 



5-238 



20. Is LBL going to field-test wet flex? What is the 
timing? What methods will be used? (Steven Hall, 
Fresno) 

21. Who in the USER will decide which option will be sent 
to the State Board as the proposed cleanup plan? 
(David Witter, Gustine) 

22. Who has the authority to approve the plan that is 
finally selected; the USER or the State Board? (David 
Witter, Gustine) 



5-239 



7, 
8. 



10 



Socioeconomic impacts and mi ti rr^<--; ^,, 

in Sections 4j t';.rough 4m of ?he Draft'^E'i?' '^S ^^ — -^ 
selected to mitigate significant impacts .;. J^ "^e^^ures 
the Final EIS. impacts are described in 

The suggested chanqe is Prli i-o-,--; = i • 

change the essential conclusions of" tT'"n" .""^ ^°^^ "°t 
USER and its consultants have f^f/n, l^ ^""^^^ ^^^ ' The 
Kesterson Program EIS Tn a manner thT^"^ u° °^5^"i^e the 
and easy to follow it it r-Tnr. ^ ^^ ^°^^ informative 

approaches could also haJe.?o^"^?-^ .^^^^ °^^^^ editorial 
less technical sumi^ary of the ^DraTt'^'E^'^^^^^ '^"'" ^°^^^- ^ 
^g^^^^ased to^the pu.lL"fs Si^T^^^^^ 

de^is^'o^n^^^^Lrrrr -J''agtrcrt^d%\tl -^^^^^^^^^ P-^-^ 
will be implemented as part of thi^"^^'^ involvement that 
USER is ultimately responSble for ^1''°^°"^.^ ^^^i°"- ^he 
xveness of each ph'ase orthe' p^ op oL? actio n^"^ ''^ ^''^^^- 
Please see response to comment 3. 
Please see response to comment 3. 

L'stL\"^thf'i„tlcT/\^„=,'^:-:-J^3^„h|^"3BR has proposed for 
ducing the extent of '" ^^^^^^^iveness of discing for re- 
the n?rth ponSs is a veaet^.'^^'i''"' contamination. Discing of 
the proposed action? ''^^^^^^^°^ ^°"trol measure included in 

The alternative of usina the <^Tn ^-^ 

mitigation wetlands was e.^Xu^tlf in°t^77rZtZsr'''' '° 

Dr^ft"'B\'sr^'on7-«nt;'and^UYonar '"^ P-P«ation for the 
Reservoir cleanup, 'as descrih^S ""pacts of the Kesterson 

the alternatives'^has the potentialto %?"" "=' "°"^ °« 
beyond the vicinity of the^^Kesterson'^R!""" "'*" '"""'^^ 

bec\u"srt'hV°p"ro^L'Jd"artron/\re'iffr' /" ^^^ -° "^= 
Program No-Action AlternatTv^ ," different. The Kesterson 

water flows in the SLD^nr!,, ! T^ termination of draln- 
1985 agreement. Whereas the r".'"^ °°"^'™'^ *P"1 3, 
Nc-Action Mternatlve^rsLes'^^hefe "f'lrs^-w^i co-nSe. "^ 

deLrfp^lTn'Tn Ty.ls' ^ ,Hi%\7 ''':^ /" '*'<= P-P°-d action 
local shallow grounLater IM' ^f II ^^ ""derate-salinity 
than a low-salinity watlr'suoofv w,??'^ T""" ="^^1^ "'her 
ecological changes^n tZ K^TeLZ'LlttZlrronL:' ""^^""^ 



5-240 



11. The USER believes that it can begin implementation of the 
proposed action by February 5, 1988, notwithstanding the 
environmental documentation and permitting requirements 
discussed in the Draft EIS. See response to comment 15 
below. 

12. The ultimate determination of which entity (or entities) 
will bear the cost of cleanup and postclosure maintenance 
of Kesterson lands and/or the development of new waterfowl 
management areas is beyond the scope of this EIS. The DOI 
will, however, charge any component of such costs as are 
properly borne by CVP project users under existing 
Reclamation laws to those entities. If it is subsequently 
determined that the allocation of the repayment obligation 
for the costs of the Kesterson Reservoir closure and clean- 
up actions may result in physical environmental impacts, as 
distinct from solely socioeconomic impacts, the DOI will 
prepare supplemental environmental documentation addressing 
these effects. 

13. Under the FRP, the northern ponds will not receive applied 
water. This will result in loss of wetland habitat values; 
mitigation for this impact is being considered, as des- 
cribed in the proposed action description in this Final 
EIS. 

14. To reduce selenium mobilization risks in the northern 
ponds, these ponds will be disced and kept as dry as pos- 
sible. Groundwater monitoring will determine whether 
selenium leaching in the' northern ponds causes contamina- 
tion exceeding threshold contaminant levels; if so, a 
corrective action program would be implemented. See the 
proposed action description contained in this Final EIS. 

15. The USER'S interpretation of WQ 85-1 is that the Febru- 
ary 5, 1988 date represents the date by which implementa- 
tion of a cleanup plan must be completed, and not the date 
by which cleanup must be completed. 

16. The USER is implementing USFWS proposals for alternative 
habitat development to mitigate for ongoing wetland habitat 
value impacts. 

17. USER possesses no evidence of significant "salting up" of 
adjacent lands due to Kesterson Reservoir operations, but 
will continue to bear this concern in mind when conducting 
its monitoring program. The salt content of the applied 
water is expected to be approximately the same as that of 
regional groundwater. As a result, the "salting up" of 
adjacent land is not expected to occur. 

18. USFWS does not support implementation of the FRP. 



5-241 



19. The Draft EIS evaluated a FRP w.'^k . 

ponds wet or J^eeping air^ond^ /rT °^ni°?^ = ^"^^^"^ ^^^ 
these options into a sinqle nffn • * • "^^^ ^^^ combined 
which calls for keeping the south " '^^ P^oposed action? 
northern ponds dry. USER hJ """ P°^^s ^et and the 

monitored for 1 yeL or fon^^ """^ ^^^^' ^"^ will be 
levels were down to ?he 10 nnh^ ""• ^^^er-borne selenium 
Baseline values for selenium^ in ^H^%^' of mid-July 1985 
determined and will be repeated Iv/'/ ^^^^ ^^^^^^y beeA 
proceeds. repeatedly determined as the test 

''• ^enroTVhe'^^'L'rSr^ 1""^^''^^ °^ ^^^ Secretary, Oepart- 
mitted to the SWrJb? ' ""'' ^^^^^^^ ^^e final op'^t'ion "^^ub- 

22. The SWRCB has assert^rl >- 

operation and cleanup of Kr.l^^'"'^ jurisdiction over the 
law. The Board is re^quiring thf?°?h ^^^^^^^^ under staS 
for compliance with the swrcb • s ^^5^ "^/"^ ^^^^^^ the CPM? 
approval. The USBR ha^ ,,^7? ^, °^^er for its review and 
development of a ni^n / utilized the NEPA process !n ?hf 
SWRCB ^isappJo've^'an'y o^alf ^f'^r T '^' '^^'^ "^ thi 
between the SWRCB and ?he USbR will f^^"' ^"^^ disagreement 
accordance with applicable law . ^^^.^ ^° ^^ resolved in 
possible legal issues attendina J^^^ discussion of thS 
beyond the scope of this Eir "^ ^^^^ ^^^^^^ process is 



5-242 



Chapter 6 



REFERENCES 



The references listed here are those cited in the Final EIS 
(Volume I) and not included in the References section of the 
Draft EIS (Volume II of the Final EIS) . 



References Cited 



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6-1 



Brinson, M. M. , A. E. Lugo, and S. Brown. 1981. Primary 
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6-2 



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6-3 



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6-4 



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an aquatic food chain. Pp. 67-76 in First Annual 
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Institute. Fresno, CA. 

Sandholm, M. , et al. 1973. Uptake of selenium by aquatic 
organisms. Limnology and Oceanography 18:496-499. 

Sarathchandra, S., et al. 1981. Oxidation of elemental 
selenium to selenite by Bacillus megaterium . Science 
211:600-601. 

Segawa, R. T., L. J. Ross, and J. J. Troiano. 1985. Monitoring 
selenium, nickel, and chromium concentrations in agricultural 
commodities in the western San Joaquin Valley, 1984. Draft 
report - April 1985. California Department of Food and 
Agriculture. Sacramento, CA. Prepared for: U. S. Bureau of 
Reclamation as required by Contract No. 5-FC-20-02800 . 

Sharma, D. C. and P. S. Davis. 1980. Behavior of some 
radioactive compounds of mercury and selenium in aquarium 
water and their direct uptake by the goldfish, Carassius 
auratus . Indian Journal Experimental Biology 18:69-71. 

Shaver, G. R. and J. M. Melillo. 1984. Nutrient budgets of 
marsh plants: efficiency concepts and relations to 
availability. Ecology 65:1491-1510. 

Sorenson, E. M. B., et al. 1982. Selenium accumulation and 
cytotoxicity in teleosts following chronic, environmental 
exposure. Bulletin of Environmental Contamination Toxicology 
29:688-696. 

. 1984. Histopathological, hematological condition 

factor, and organ weight changes associated with selenium 
accumulation in fish from Belews Lake, North Carolina. 
Archives Environmental Contamination Toxicology 13:153-162. 



6-5 



Sorenson, E. M. B., J. S. Bell, and C. W. Harlan. 1983. 
Histopathological changes in selenium-exposed fish. American 
Journal of Forensic Medicine Pathology 4:111-123. 

Texas Utilities Generating Company. 1986. Martin Creek 
Reservoir selenium monitoring program. Texas Utilities 
Generating Company. Dallas, TX . Unpublished report. 

Tinson, S. and J. Laybourn-Parry . 1985. The behavioral 
responses and tolerance of freshwater benthic cyclopoid 
copepods to hypoxia and anoxia. Hydrobiologia 106:219-231. 

Torna, A. and F. Habashi. 1972. Oxidation of upper (II) 
selenide by Thiobacillas ferroxidans . Canadian Journal of 
Microbiology 18:1780-1781. 

Webb, D. W. 1981. The benthic macroinvertebrates from the 
cooling lake of a coal-fired electric generating station. 
Illinois Natural History Survey Bulletin 32:358-377. 

Wehr, J. D. and L. M. Brown. 19 85. Selenium requirement of a 
bloom- forming planktonic alga from softwater and acidified 
lakes. Canadian Journal of Fish and Aquatic Science 
42:1783-1788. 

Wetzel, R. G. 1975. Limnology. W. B. Saunders Company. 
Philadelphia, PA. 743 pp. 

Wilson, C. J. and G. Tchobanoglous . 1986. The role of wetlands 
in the removal of selenium from subsurface agricultural 
drainage. Pp. 137-148 in Symposium on Selenium in the 
Environment, California State University, Fresno, June 10-12, 
1985. (CATI-860201) . California Agricultural Technology 
Institute. Fresno, CA. 

Woock, S. E. and C. R. Cofield. 1983. Roxboro Steam Electric 
Plant Environmental Monitoring Studies. Technical Report, 
Volume II, Carolina Power and Light Company. New Hill, NC . 
80 pp. 

Woock, S. E. and P. B. Summers. 1984. Selenium monitoring in 
Hyco Reservoir (NC) waters (1977-1981) and Biota (1977-1980) . 
Pp. 6-1 to 6-27 in Workshop Proceedings: the effects of trace 
elements in aquatic ecosystems. (Pub. EA-3329, Project 1631.) 
Electric Power Research Institute. Palo Alto, CA. 



Personal Communications 

Hoffman, G. December 19, 1984. Research Leader. USDA Agricul- 
tural Research Service, Water Management Research Laboratory, 
Fresno, CA . Letter to W. G. Chase, USDA Agricultural Research 
Service . 



6-6 



Home, A. J. August 1, 1986. Professor of Applied Ecology, 
Department of Civil Engineering, and Biologist, Sanitary 
Engineering and Environmental Health Research Laboratory, 
University of California, Berkeley, CA. Telephone 
conversation. 

Lowe, P. September 2, 1986. Research Biologist. U. S. Fish 
and Wildlife Service, Patuxent Wildlife Research Center. 
Laurel, MD. Telephone conversation. 

McKevitt, J. September 3, 1986. Field Supervisor, Division of 
Ecological Services. U. S. Fish and Wildlife Service, 
Sacramento, CA. Memorandum. 

Smith, G. August, 1986. Drainwater Research Coordinator. 
U. S. Fish and Wildlife Service, Patuxent Wildlife Research 
Center. Laurel, MD. Telephone conversation. 

Volz, M. G. October 29, 1985. Environmental biochemist, group 
leader/environmental measurements. Department of Health 
Services, Berkeley, CA. Letter and unpublished data. 

Wallenstrom, R. August 18, 1986. Regional Director. U. S. 
Fish and Wildlife Service. Portland, OR. Memorandum to 
Regional Director, U, S. Bureau of Reclamation. 



6-7 



6-8 



Chapter 7 



AGENCIES AND INDIVIDUALS RECEIVING COPIES OF 
THE DRAFT AND FINAL EIS 



The Draft and Final EIS has been distributed to the follow- 
ing agencies, organizations, and individuals. In addition, a 
notice of availability of the Draft EIS was sent to approxi- 
mately 4,200 persons and agencies who have expressed an interest 
in the EIS subject matter. 



Federal Agencies 
(To be distributed by the Commissioner, Bureau of Reclamation) 

U. S. Department of the Interior 

Bureau of Indian Affairs 

Bureau of Land Management 

Bureau of Mines 

Fish and Wildlife Service 

Geological Survey 

National Park Service 

Western Regional Office - Secretary of the Interior 

Other Federal Agencies 

Advisory Council on Historic Preservation 
Department of Agriculture 
Department of the Army 
Department of Commerce 
Department of Energy 

Bonneville Power Administration 

Federal Energy Regulatory Commission 
Department of Health and Human Services 
Department of Housing and Urban Development 
Department of Transportation 
Environmental Protection Agency 

U. S. Senators 

Honorable Alan Cranston 
Honorable Pete Wilson 



7-1 



U. S. Congress 



Honorable 


Barbara Boxer 


Honorable 


Sala Burton 


Honorable 


Tony Coelho 


Honorable 


Ronald V. Dellums 


Honorable 


Don Edwards 


Honorable 


Vic Fazio 


Honorable 


Tom Lantos 


Honorable 


Richard Lehman 


Honorable 


Robert T. Matsui 


Honorable 


George Miller 


Honorable 


Norman Mineta 


Honorable 


Leon Panetta 


Honorable 


Charles Pashayan, Jr. 


Honorable 


Norman Shumway 


Honorable 


Fortney H. (Pete) Stark 


Honorable 


William Thomas 


Honorable 


Ed Zschau 



Federal Agencies 

(To be distributed by the Regional Director, Bureau of 
Reclamation, Mid-Pacific Region) 



U. S. Department of the Interior 

Assistant to the Secretary, DOI , Sacramento, CA 

Bureau of Indian Affairs, Sacramento, CA 

Bureau of Land Management, Sacramento, CA 

Bureau of Mines, Spokane, WA; Washington, DC 

Fish and Wildlife Service, Portland, OR; Sacramento, CA, 

Los Bancs, CA; Columbia, MI 
Geological Survey, Sacramento, CA, Menlo Park, CA (2); 

Re St on, VA 
National Park Service, San Francisco, CA 
Regional Environmental Officer, DOI, San Francisco, CA 



Other Federal Agencies 

Corps of Engineers, 

Sausalito, CA 
Department of Health 

Rockville, MD 
Environmental Protection Agency, San Francisco, CA 
Federal Highway Administration, San Francisco, CA 
Food and Drug Administration, Rockville, MA 
Forest Service, San Francisco, CA 
National Marine Fisheries Service, Tiburon, CA 
Soil Conservation Service, Davis, CA, Los Banos, CA 
Western Area Power Administration, Sacramento, CA 



Sacramento, CA, San Francisco, CA, 
and Human Services, San Francisco, 

(2) 



CA; 



7-2 



state Agencies 

State Senate 

Honorable Ruben Ayala 

Honorable Daniel E. Boatwright 

Honorable John Garamendi 

Honorable Kenneth L. Maddy 

Honorable Dan McCorquodale 

Honorable Henry J. Mello 

Honorable Jim Nielsen 

Honorable H. L. Richardson 

Honorable David Roberti 

Honorable Walter W. Stiern 

Honorable Rose Ann Vuich 



State Assembly 

Honorable Rusty Areias 

Honorable Bruce Bronzan 

Honorable Gary Condit 

Honorable Dominic L. Cortese 

Honorable Jim Costa 

Honorable Phil Isenberg 

Honorable Patrick Johnston 

Honorable Bill Jones 

Honorable Don Rogers 

Honorable Norman S. Waters 

Honorable Phillip D. Wyman 

State Agencies (California) 

California Assembly Committee on Agriculture, Sacramento 
California Assembly Committee on Water, Parks and Wildlife, 

Sacramento 
California Assembly Natural Resources Committee, Sacramento 
California Assembly Office of Research, Sacramento 
California Chamber of Commerce, Sacramento 
California Coastal Commission, San Francisco 
California Department of Conservation, Sacramento 
California Department of Fish and Game, Sacramento, 

Stockton, Fresno 
California Department of Food and Agriculture, Sacramento 
California Department of Health Services, Sacramento (2), 

Fresno, Berkeley 
California Department of Parks and Recreation, Sacramento 
California Department of Transportation, Sacramento 
California Department of Water Resources, Sacramento, 

Fresno (2) 
California Office of Historic Preservation, Sacramento 
California Regional Water Quality Control Board, Central 

Valley Region, Sacramento (2) , Fresno 

7-3 



California Solid Waste Management Board, Sacramento 
California State Clearinghouse, Sacramento (20 copies) 
Office of Governor Deukmejian, Sacramento 
State Attorney General's Office, San Francisco 
State Lands Commission, Sacramento 
State Reclamation Board, Sacramento 
State Water Resources Control Board, Sacramento 
University of California, Water Resources Center Archives, 
Berkeley 



Local Agencies 



Broadview Water District, Firebaugh 

Central California Irrigation District 

Central Delta Water Agency, Stockton 

City of Firebaugh 

City of Gustine 

City of Los Bancs 

City of Mendota 

City of Merced 

Columbia Canal Company, Dos Palos 

Contra Costa Water District, Concord 

Firebaugh Canal Company, Mendota 

Fresno County Administrator, Fresno 

Fresno County Agricultural Commission, Fresno 

Fresno Public Works and Development Services Department, 

Fresno 
Grassland Resource and Conservation District, Los Bancs 
Grassland Water District, Los Bancs 
Kern County Board of Supervisors, Bakersfield 
Kern County Department of Planning and Development 

Services, Bakersfield 
Kern County Water Agency, Bakersfield 
Kings County Board of Supervisors, Hanford 
Los Angeles Department of Water and Power, Los Angeles 
Merced County Board of Supervisors, Merced 
Merced County Health Department, Merced (2) 
Merced County Office of County Counsel 
Merced County Planning Commission, Merced 
Monterey County Board of Supervisors, Salinas 
Panoche Water District, Firebaugh 

San Joaquin County Board of Supervisors, Stockton 
San Luis Canal Company, Dos Palos 
Solano County Department of Environmental Management, 

Fairfield 
Tranquillity Irrigation District, Tranquillity 
Westlands Water District, Fresno 



Other Agencies and Organizations 

Association of California Water Agencies, Sacramento 
California Central Valley Flood Control Association, 
Sacramento 

7-4 



California Chamber of Commerce, Sacramento 

California Farm Bureau, Sacramento, Fresno, Merced 

California Natural Resources Federation, Sacramento 

California Waterfowl Association, Sacramento 

Chapman Forestry Foundation, Davis 

Community Alliance for Responsible Water Policy, Mendota 

Defenders of Wildlife, Sacramento 

Ducks Unlimited, Sacramento, Stockton 

Environmental Defense Fund, Berkeley (2) 

Friends of the River, Sacramento 

Kesterson Properties, Beverly Hills 

Land Preservation Association, Fresno 

Lawrence Berkeley Laboratory, Berkeley 

League of Women Voters, Sacramento 

National Audubon Society, Sacramento 

National Wildlife Federation, Washington, DC 

Natural Resources Defense Council, San Francisco 

Planning and Conservation League, Sacramento 

Red Tape Abatement, Ltd., Sacramento 

Sierra Club, San Francisco, Oakland, Sacramento 

The Nature Conservancy, San Francisco 

Waterfowl Habitat Owners Alliance, San Marino 

Wildlife Society, Fresno 



Individuals 

Richard L. Anderson 

Roy Anderson 

A. F. and M. E. Baca 

Roy Bailey 

David Bainbridge 

Baker, Manock and Jensen (Attn: Mike Campos) 

Barbara Duck Club (c/o Gene Fletcher) 

Matthew Barcellos 

J. A. Bettencourt, Jr. 

Jennie Bravinder 

David Britz 

Michael J. Brophy 

Sidney Brown 

Hal Candee 

Lloyd Carter 

A. Dale Chapman 

Cherokee Cattle Ranch (c/o R. P. Tolles) 

Clearwater Land & Cattle Co. (c/o Albert J. Locatelli) 

Donn R. Cobb 

Cecilia Connerton 

Jim Cooper 

Allen B. Coutchie 

Robert Crandall 

Gaylen Crubb 

Ed Cummings 

W. Czajkowski 

David R. and Doris O. Dawdy 



7-5 



Lena DeArmond 

Oscar De Los Rios 

William Doyle 

Dan Dudek 

Hugh Durham 

Eighty Gun Club 

Bruce F. Eldrige 

Noel and Edna Featherstone 

M. G. and R. L. Fields 

Brooke Fitzgerald 

Scott Frazer 

Anna Freitas 

Irma Freitas 

Jeanette Freitas 

Wilbur and Irene Gomes 

Marguerite Gould 

John Gray 

Jim Green 

Sharon Hagen 

Paul Hendrix 

Rick Himes 

Patrick Holden 

Hollister Land & Cattle Co. 

Hollow Tree Land & Cattle Co. (c/o H. R. Sites) 

Harold Horsley 

Alice 0. Howard 

Farouk T. Ismail, Ph.D., P.E. 

Doug James 

Leo Johnson 

Lynell Johnson 

E. R. Johnston 

Gerald E. King 

Laura King 

Jeff Kerny 

Bob Kleinsmann 

Tom Kruzic 

A. O. Lang 

Cheryl Langley 

Dennis Lemly 

Cynthia Lenhart 

Don Levenhagen 

Lone Tree Land & Cattle Co. (c/o S. Hewlett) 

Manteca Land Company (c/o Bruce loppini) 

Blaine McAfee 

Joe McGahan 

Emil McHenry 

Daniel C. McLean 

A. L. and F. L. Mello 

Dr. Roland Meyer 

Melvin Moriguchi 

Trish Muluey 

Newman Gun Club 

William Norman 



7-6 



Nancy Pearson 

Molly Penberth 

Richard Pinkham 

David Powell 

Jay Punia 

Jeff Roche 

Jim Roger 

Ivan H. Roscoe 

William Ross 

Ferdinand S. Ruth 

Luis Saguinsin 

Dr. E. J. Salmon 

Dr. James Sandos 

Santa Fe Land & Cattle Co. (c/o F. R. Bambauer) 

Andy Schiffrin 

R. M. Scholl 

Joanne Schneiter 

Dr. Gerhard Schrauzer 

C. M. and J. L. Schwab 

John Seasholtz 

Manual L. Silva 

Rita Singer 

Richard M. Sitts, Ph.D. 

Dr. Greg Smith 

J. O. Souza, Sr. 

William R. and Donna G. Souza 

Steve Spickard 

Brian D. Sujata 

Shelli Thomas 

Alan Thum 

Jim Tischer 

Kenneth W. Walsh 

Nancy Wantz 

Pam Whiteley 

Jan Whittington 

John Williams 

Craig Wilson 

J. M. Winten 

Wolfsen Land & Cattle Co. (c/o Simon Newman) 

Dave Wegner 

John Wolfe 

Harold Wollenberg 

Jim Yost 



Newspapers 

Firebaugh - Mendota Journal 

Fresno Bee 

Hanford Sentinel 

Kerman News 

Los Bancs Enterprise 

Merced Sun Star 

Modesto Bee 

7-7 



Sacramento Bee 
Sacramento Union 
San Francisco Chronicle 
San Francisco Examiner 
The Gustine Standard 
Visalia Times - Delta 



Libraries 

Beale Memorial Library, Bakersfield 

California State Library, Sacramento (13) 

Colorado State University, Fort Collins, CO 

Contra Costa County Public Library, Concord Branch, Concord 

Fresno County Free Library, Fresno Branch, Fresno 

Fresno County Free Library, Mendota Branch, Mendota 

Merced County Library, Gustine Branch, Gustine 

Merced County Library, Los Bancs Branch, Los Bancs 

Merced County Library, Merced Branch, Merced 

Monterey Public Library, Monterey 

Sacramento Public Library, Sacramento 

San Francisco Public Library, San Francisco 

San Luis Obispo City-County Library, San Luis Obispo 

Santa Barbara City Library, Central Branch, Santa Barbara 

Stanislaus County Public Library, Modesto 

Stockton-San Joaquin County Public Library, Stockton 

Tracy Public Library, Tracy 

University of California, Los Angeles, Santa Barbara, 

Davis, Berkeley (21) 
University of Montana Environmental Library, Missoula, MT 



7-8 785-055/45808 



LIBRARY . MP mm 

2800 COTTAGE WAY 
SACRAMENTO. CA 95825-1898